For each of the following independent cases, indicate whether you believe any penalty would be assessed under ITA 163.2-on any of the parties involved. Explain your conclusion. Case 1 A company has established a limited partnership by acquiring a software application from a non-arm's length individual for $450,000. Units in the limited partnership are being sold by the company. The prospectus for the offering states that the fair market value of the acquired application is $10 million, a value based on the work of an independent appraiser. The limited partnership is registered with the CRA as a tax shelter. On audit, the CRA determines that the $450,000 paid for the software application is, in fact, its fair market value on the date of the transfer. In questioning the approach used by the appraiser, that individual indicated that his work was based largely on assumptions provided by the com- pany sponsoring the limited partnership offering. The appraiser's fee for the work was $150,000.