R. v. Ling, 2002 DTC 7566, 2002 SCC 74, [2002] 3 SCR 814 -- summary under Subsection 231.1(1)

CCRA was conducting an audit and not an investigation of the taxpayer up until the time of a three-hour meeting in which the taxpayer was questioned extensively about unidentified deposits and unreported income. Accordingly, evidence gathered prior to and during that meeting was properly obtained as part of the audit process and could be shared with Special Investigations, whereas evidence gathered subsequent to that meeting and prior to warning him that he was the subject of an investigation for the purposes of furthering an s. 239(1) prosecution, violated the taxpayer's Charter rights and would have to be reconsidered in light of s. 24(2) of the Charter at a new trial.