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In his review, the analyst considered each of the points raised in the requests, commented on those points one by one and concluded in each case that the Guidelines did not apply to the applicant’s circumstances. ... However, the decision of July 3, 2008 briefly described the analyst’s review and considered each of the points raised by the applicant before concluding that the request was denied. ...

The Court has nonetheless considered the general arguments raised in the written memorandum and oral submissions of counsel for the MPA ...   [21]            Relying on what PWGSC was doing, the CBC informed all the taxing authorities, in a letter dated November 27, 2002, signed by Tim Neal, Chief, Business Management and Administration, CBC/Radio-Canada Transmission (the CBC Policy), that a new PILT application form would be used from then on and that in the processing of applications for PILT and LPS payments, the terms set out in the CBC Policy would be considered. ...

If the answer to either of these questions is “NO”, the disclosure may be considered voluntary. ...   [43]            I therefore find that the Respondent is estopped from denying that the Applicant is entitled to be considered as having met condition 6(a) of the Information Circular 00-IR in effect on September 16, 2005 ...

    [28]            The test in section 204.1(4) is conjunctive, meaning both prongs must be established to the satisfaction of the Minister before a taxpayer will be considered for relief.   ...   [32]            The scope of the discretion accorded the Minister was considered in Jenkins v Canada (Revenue), 2007 FC 295, Justice Pierre Blais held at para 13: …it is important to keep in mind that the power of the Minister, as set out in subsection 220(3.1) of the Act, is a discretionary power and as such, there is no obligation on the part of the Minister to reach any given conclusion. ...

Issues [2] The issues in these appeals are: (1) Can the Appellant's home be considered a "nursing home" for the purposes of paragraphs 118.2(2)(b) and (d) of the Income Tax Act (the " Act ")? If the answer to number (1) is in the negative, then alternatively: (2) Can the Appellant's home be considered an "other place" for the purposes of paragraph 118.2(2)(e) of the Act? ...

  [7]                In spite of my concerns about the failure of counsel to raise this matter earlier, I have considered his submissions and find that they are without merit. ...   [18]            Where an “extraordinary circumstance beyond the person’s control has prevented the person from complying with the Act”, paragraph 9 of the memorandum sets out a number of factors that “will” be considered to determine whether the penalties and interest should be waived. ...

The fact that you misunderstood the term “unused” is not considered a reasonable error. ... Is not the elimination of the error considered as a reasonable step to correct that error?             ...

The fact sheet showed a liquidity ratio of 0.01285, when a ratio of 2.0 is generally considered sufficient for a company to meet short term needs. The debt ratio was 1,120.47, where a ratio over 1.0 is considered not solvent. ...

He considered the delay to be excessive and attributable to the CRA. According to the Officer, none of the other delays or any error could be attributed to the CRA. [19]            In addition, the Officer concluded that the TCC had upheld all of the assessments challenged by the applicant and that he had lacked diligence by deliberately letting interest accrue on his tax debt. ... Furthermore, he claims that the notice of assessment under section 160 is also invalid, and that the CRA’s decision to issue this notice of assessment was an abuse of power, given that the applicant was no longer a shareholder in Sécovac. [24]            In essence, the applicant contends that the Officer ought to have agreed to waive the interest in order to compensate for the actions of CRA representatives, which he alleges were marked by bad faith and deception in addition to being knowingly misleading. [25]            With respect to the assessment under paragraph 39(1)(c), the applicant asserts that the Officer ought to have considered the argument according to which he would not have initiated the present legal proceedings had the CRA informed him that he could not declare an ABIL, as his company had been struck off the register on May 5, 2000. ...

As a result, the panel did not believe that her problems were related to the alleged events. [23]   The panel concluded that the applicant was not credible with respect to the essentials of her allegations concerning her fears of persecution. [24]   Since the jurisprudence has confirmed that in the case of women, it is important to proceed with a careful analysis to verify if the particular circumstances and the documentation on the country indicate that they could be considered to be victims of persecution, the panel analyzed the context in the Ivory Coast. ... [41]   The applicant holds that the Member ignored relevant pieces of evidence, concluding that there was not a serious risk of persecution based on the fact that she was a member of the social group of women. [42]   The Member recognized her obligation to proceed with a careful analysis to verify if, because of the particular circumstances and documentary evidence concerning sexual violence against women, the applicant could not be considered to be a victim of persecution. [43]   The applicant’s main argument was that the member did not take into account all of the documentation on the situation in the country when she stated that violence against women was sporadic, occurring more frequently during wars or elections. ...