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”   [61]            In her reasons the decision maker considered that the Applicant has three children attending University in Ontario and Quebec and found: It is commendable that you would like to support your children in their educational endeavours; however, the costs of providing post-secondary education is not considered a basic necessity, and therefore is not considered in determining financial hardship for the purposes of the Taxpayer Relief Provisions ...   [75]            The Applicant’s inability to earn income was considered by the decision maker and she determined that no further relief would be granted ... In this situation, I find the decision maker’s application of the facts to the criteria for granting relief is reasonable when the timeline is considered.         ...

It is only under quite exceptional or unusual circumstances that such an operation should be considered as a speculation. ... At this point, the decision of this Court in MNR v Steer, [1967] S.C.R. 34: [1966] CTC 731, must be considered. ... In my view, the payments made by respondent could not properly be considered as an investment in the circumstances in which they were made. ...

Villeneuve (Respondent’s Record, p 200)). [20] On July 19, 2019, the Appeal Panel considered that Mr. ... Kenney submits, is not a factor to be considered under Table 4. · Bathing: While Mr. ... Kenney in relation to the six elements to be considered in determining the grade level. ...

However, the Department has made a distinction between instalment payments of a specified sum payable, which it considered not deductible, and regular payments on account of a specified sum payable, which it considered deductible. This latter type of payment was considered deductible by the Department if the wording in the written agreement or order indicated that the total amount subject to regular payments was for maintenance, that the regular payments were consistent with that purpose, and that the payments were spread over an extended period of time. ... If, however, there are only a few payments to be made, spread over a relatively short period of time in satisfaction of a specified sum payable, such smaller payments may be considered instalments on a lump-sum payable and not deductible: No. 107 v. ...

Miller's assertion (corroborated by her accountant) that the 1998 tax return had been prepared and mailed on time was considered. There is no indication that the date of completion indicated on the 1998 tax return (April 20, 1999) was considered. ... Miller's entire compliance history was considered nor is there an indication that consideration was given to serious emotional or mental distress. [11]            While it is not open to me to substitute my opinion for that of the ministerial delegate, neither is it my function to speculate on what the ultimate decision might have been had all relevant factors been considered. ...

According to that approach, a person who had established a residence in Canada could be considered a resident even if he or she were temporarily out of the country for business, vacation, or schooling. ... Once a person has a firm footing in Canada, he or she can be considered a Canadian resident even when outside the country temporarily. The Citizenship Act imposes a residency requirement, not a physical presence requirement, so the question is whether an applicant could be considered to be a Canadian resident even when outside the country on temporary business. ...

However, this is not a sufficient basis to argue that evidence was ignored or misconstrued. [19]   The factors considered by the Visa Officer including: travel history, family ties in their   home country, employment, and financial status have all been accepted by this Court as relevant factors for officers to consider in deciding applications for temporary resident visas (see Obeng v Canada (MCI), 2008 FC 754 at para 13; Huang v Canada (MCI), 2012 FC 145 at para 11; Skobrev v Canada (MCI), 2004 FC 485 at para 8; and Baylon v Canada (MCI), 2009 FC 743 at paras 26). ... It is the Visa Officer, and not this Court, who makes this determination based upon a review and a consideration of the factual evidence provided by the Applicant. [21]   Although the Applicants claim that the Visa Officer failed to consider their evidence, this claim is not supported by the decision which shows that the Officer considered the evidence but had concerns with the evidence. ... The Officer considered the evidence provided by the Applicants and provided his reasons as to why the evidence did not convince him that the Applicants would leave Canada at the end of their authorized stay.   ...

The RPD considered whether it would be unduly harsh to expect the Applicants to relocate to Port Harcourt. It also considered the Applicants’ arguments that they would face difficulty because they lack friends and family there. The RPD also considered religious, economic and cultural factors and whether and how those factors affect women in the IFA. ...

The dispute arises out of the remaining $130,000 which consisted of prepaid interest and revolves around the question whether that amount should be considered as income for 1980 or considered as income attributable to the entire term of the mortgage, that is, up to the 31st of December 1984, when the whole of the principal of $300,000 became payable in one lump sum. ... Where the income under consideration is part of the normal business activity of a company and it is inextricably linked with an active business it is considered active business income. ... The interest, in my view, must be considered as “receivable” in that year, by whatever dictionary or technical accounting definition one might attribute to the word “receivable”. ...

The third alternative, recording the bonus in 1976, was considered by the expert as acceptable and even preferable, if the loan was to be considered very risky, “of such severity as to question the recoverability of the loan”. ... Moreover, the land in question mortgaged to the lender was considered to be worth at least $1,000,000 and probably much more. ... In my view the subsection does not apply to the bonus in question which cannot be considered to be “a debt that was then payable”. ...