Ray v. Canada, 2004 DTC 6028, 2004 FCA 1 -- summary under Section 18.24

In rejecting a submission that deference should be given to the interpretation given by the Tax Court below in interpreting s. 118.2(2)(n) of the Income Tax Act, Sharlow J.A. stated (at p. 6031) that "decisions of the Tax Court and questions of law are to be reviewed on the standard of correctness, regardless of the procedure under which the decision was made".