In Kiperchuk v R, 2013 TCC 60, the Tax Court held that a widow was not the “spouse” of her deceased husband. In Enns v R, 2023 TCC 28, however, the Court followed Kuchta v R, 2015 TCC 289, and held that a widow was a “spouse” of her deceased husband, who was a tax debtor at death, for the purposes of section 160 of the Income Tax Act (Canada).
