The Appellant was represented by counsel when he negotiated and signed the Agreement and when he agreed to fund the purchase of the annuities for his former spouse. He was also represented by counsel when it was decided how he would fund the purchase of the annuities. His liability for income tax does not depend on the Agreement between him and his former spouse but on the application of the relevant sections of the Act. (Ouellet v. The Queen (2000), 55 D.T.C. 3688)
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