Maege v. The Queen, 2006 DTC 3193, 2006 TCC 117, aff'd supra -- summary under Tax Shelter

In finding that the taxpayer's investment in a partnership was a tax shelter notwithstanding that she did not receive any representations as to the tax consequences of her investment, Rip J. stated at p. 3200) that "a 'representation' need not be an explicit written or verbal assertion but can also include a mental or intellectual element" and that this was "further reinforced by the definition of 'proposed' or 'proposal', which seems to include one's own personal intentions".