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The Queen, [1983] 1 S.C.R. 29; [1983] C.T.C. 20; 83 D.T.C. 5041 at page 25 (D.T.C. 5045; S.C.R. 39) to the effect that the phrase "in respect of" contained words of "the widest of any expression intended to convey some connection between two related subject matters". ...

The motions judge was right in finding that the existence or absence of such connection was strictly a question of law to be answered in the light of the provisions of the Income Tax Act, the Constitution Acts 1867 to 1982, and the Financial Administration Act. ...

The following provisions of the Estate Tax Act* [1] should be considered in connection with this appeal: 7. (1) For the purpose of computing the aggregate taxable value of the property passing on the death of a person, there may be deducted from the aggregate net value of that property computed in accordance with Division B such of the following amounts as are applicable: (a) the value of any property passing on the death of the deceased to which his spouse is the successor that can, within six months after the death of the deceased or such longer period as may be reasonable in the circumstances, be established to be vested indefeasibly in his spouse for the benefit of such spouse, except any such property comprising a gift made by the creation of a settlement or the transfer of property to a trustee in trust; (2) For the purposes of paragraph (1)(a), any superannuation, pension or death benefit payable or granted (a) out of or under any fund or plan established for the payment of superannuation, pension or death benefits to receipients, or (b) out of the revenue of Her Majesty in right of Canada or a province or under or subject to any Act of the Parliament of Canada or of the legislature of a province, to the spouse of a deceased on or after the death of the deceased in respect of such death, subject to a provision that such benefit ceases to be payable to such spouse if he remarries, shall not, by reason only of such provision, be considered not to be vested indefeasibly i in him. 62. (1) In this Act “settlement” includes (a) any trust, whether expressed in writing or otherwise, in favour of any person, and, if contained in a deed or other instrument effecting the settlement, whether or not such deed or other instrument was made for valuable consideration as between the settlor and any other person, and (b) any deed or other instrument under or by virtue of which a usufruct or substitution is created or any real property or estate or interest therein stands limited to any persons by way of succession: As I see the matter, there are two hurdles that the appellant must surmount to succeed in this appeal, viz: (a) it must be established that the “property” the value of which it is wished to deduct under paragraph 7(1)(a) was not “property comprising a gift made by creation of a settlement” (which by definition includes an “instrument under or by virtue of which... a substitution is created”) so as to be excluded from paragraph 7(1)(a) by the concluding words thereof, and (b) it must be established that the “property” the value of which it is wished to deduct under paragraph 7(1)(a) was “vested inde- feasibly” in the widow “for the benefit of” the widow, or, as it is put in the French version, that the property was “dévolus irrévocablement à son conjoint au profit de ce dernier”. ...

At page 16 [pp 525-6] of his reasons the learned trial judge makes these important findings: On the contrary, it is abundantly clear that he was- at all times under the direction of Dr Keevil Senior and his business associates who had employed him for many years and this arrangement was by no means terminated or altered in connection with this specific project. ...

With respect to the argument in connection with the TOM 11 for CRA investigations, the Judge rightly noted that the TOM 11 “is a set of guidelines that have no binding legal effect and their breach is not evidence per se of a wrongful prosecution or negligence” (Judge’s decision at para. 168). ...

He was also able to cross-check that information with the records from the mailing centre. [18] I agree with the appellant that the evidence establishing continuity of the notice of assessment’s path from preparation through transmission could have been brought into sharper relief during the examination-in-chief and that the connection between the appellant’s notice of assessment and cycle 1927 would have benefitted from more explicit elucidation. ...

That conclusion was characterized as a major error since, it was said, all of the evidence demonstrated hard bargaining including the uncontradicted, unimpugned testimony of three witnesses who had, at the time of the trial, severed all connections with the Pillar group. ... Stracey, who had not severed his connection with the group, who said, for example, at Transcript, Vol. 2. p. 269, lines 27 to 30, under cross-examination, Whether you use the words bargain, talk or negotiate I am telling you under oath that I did my very best at all times to get the best possible price I could from Pillar International. ...

There is no connection here between the appellant's employment income and the Peepeekisis Reserve in Saskatchewan. [19]      The necessity argument is based on the connection between the MIEA and the services performed by the appellant on the one hand, and students from various reserves in Manitoba on the other. ...

.); affirmed [1989] 1 S.C.R. 141, 91 N.R. 63 Lacombe J.A. said the following (at pages 88-9 (N.R. 218): In accepting the applicant’s argument of estoppel by representation on grounds of equity, the Court would thereby be setting aside the decision of the respondent Commission rather than that of the Umpire, and the Court is not sitting in equity in connection with the remedy currently being sought by the applicant. ... If by chance the appellants were allowed to call as witnesses taxpayers whom they knew or thought they knew had benefited from preferential treatment by the Minister it can be seen what an unfavourable position the latter would be placed in, as he could in no case present opposing evidence since he is firmly bound by the prohibition imposed on him against directly or indirectly disclosing the secret information he has in this connection. ...

A preliminary point should be mentioned in connection with 1965. As has already been indicated, the assessment was based on the assumption that the appellant purchased a property worth $344,000 from his own company for $259,000 and that payment of the price was effected by the appellant assuming mortgages in the sum of $311,000 and being given back a promissory note for $53,000. ... The question of benefit or no benefit in the 1965 taxation year is, in my view, primarily a question of fact in connection with which the onus of proof was on the appellant. ...