What is the test for making an order for equalization of net family property?

Finally, she relies on Platana J.’s decision in Francis v. Manahan, [1995] CarswellOnt 2151, where he noted that the onus to establish reasons for a sale is on the moving party. However, in refusing to make the order he relied on findings that the resisting spouse hoped to purchase the other’s interest in the home from the proceeds of equalization of net family property and a finding that the moving party was not able to show an immediate need for the money. That, of course, is not this case. Indeed, there is every reason to believe, although I make no finding, that the equalization payment in this case will flow from the wife to the husband. Finally, in Francis v. Manahan, supra, the decision was made in June with the knowledge that the trial would proceed in August.