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In connection with her final declaration above, she noted that: Sifto (which had been cited with approval in Dow Chemical) had indicated that a remedy for unreasonable conduct of the Minister could include issuing an order precluding the Minister from enforcing a penalty assessment or collecting a resulting tax debt (at para. 108); and In light of the circumstances, including that Milgram’s 2021 notices of objection had not yet been adjudicated, “quashing the Minister’s decision to reassess may therefore have the practical effect of ordering the Minister to reconsider her decision” (para. 115). ...

These secured loans had the same or similar terms as the loans referred to above in connection with the investment component, (i.e., a 2028 maturity and 7.85% p.a. interest). ...