In dealing with a submission that a Revenue Canada official had given the taxpayer some assurance that the taxpayer would not be assessed under s. 227.1, Mogan J. stated (p. 1270):
"... I doubt that any official of Revenue Canada has authority to promise a taxpayer that he will not be assessed under a specific section of the Income Tax Act if, upon a fair review of the facts, that taxpayer appears to be liable under that specific section."