Reed
J.:
The
information
before
me
does
not
demonstrate
that
the
decision
maker(s)
considered
all
the
relevant
facts
on
which
Mr.
Grant’s
application
for
a
section
220(3.1)
waiver
was
based;
Particularly,
the
failure
to
describe
the
department’s
practice
and
whether
or
not
that
was
followed
in
Mr.
Grant’s
case;
These
considerations
would
be
relevant
in
a
situation
such
as
that
in
which
Mr.
Grant
found
himself,
where
he
was
relying
upon
tax
advisers,
he
moved
geographical
location
and
changed
tax
advisers;
For
the
reasons
given,
then
the
decision
under
review
(the
decision
of
January
27,
1997
by
Mr.
Salvatore)
is
set
aside
and
Mr.
Grant’s
request
is
referred
back
for
reconsideration
by
different
departmental
officials.
Application
granted.
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