In Lev v. Lev [1992] M.J. No. 242, Scott C.J.M. wrote on whether a minority discount should be applied to the valuation of certain assets. In that case the trial judge had found that: “There is no evidence that the husband would be required to sell any of his properties…. The possibility of the husband being forced to sell his properties is merely speculative.” Scott C.J.M. agreed that no error had been demonstrated by factoring in whether the husband would have to sell his properties when considering whether the court should adjust value to reflect a minority discount.
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