The Judge’s findings of law are subject to the standard of correctness. His findings of mixed fact and law or of fact will be upheld in the absence of a palpable and overriding error (Housen v. Nikolaisen, 2002 SCC 33, [2002] 2 S.C.R. 235) [Housen]. The series of transactions and subsection 83(2.1) of the Act
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