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Guidance is also given in regards to the factors to be considered in the assessment of these factors: ¶ 33. ... (e)        All things considered, the Applicants did not qualify for taxpayer relief under the fairness provisions.   ... The relevant guidelines and factors were indeed considered in concluding as the Second Level Decision did. ...

In addition, I considered all relevant factors to determine whether it would be just, reasonable or in the public interest to recommend a remission. ... When considered together, these factors militate for a duty of fairness at the lower end of the scale. ... The following facts from the applicant’s file were also considered in refusing to recommend remission: 1. ...

Hashem had 1465 days of physical presence during the November 25, 2010 to November 25, 2016 period. [18]   In holding that it was appropriate to interpret the date of application as meaning the date of receipt in this case, the Judge considered four questions. ... Second, he considered the amount of time between the date of signature and date of receipt of the application and found that if the duration exceeded 14 calendar days, the alternative interpretation of “date of application” would not be available. ... In conducting a reasonableness review, the court can look to the record and supplement a decision-maker’s reasons where the context demonstrates that a matter was considered. ...

The Applicants’ arguments have been considered in this context. IV.   ... They acknowledge that the RAD is presumed to have considered all the evidence presented to it unless the contrary can be shown. ... The RAD considered both prongs of the IFA test and reasonably found that the Applicants would not be at risk of persecution in Ibadan. ...

While these were positive factors towards establishment in Canada, the IAD found they were not enough to outweigh what it considered to be lacking in terms of establishment. ... In that respect, the circumstances are similar to those considered in Damian (see para 18), and the applicability of that language is not determinative of this matter. ... However, there is a rebuttable presumption that it has considered all the evidence. ...

As part of their application, they submitted 15 support letters, country condition documents, a police report and a sworn declaration, all of which were considered by the Officer. ... In this case the Officer only considered the personalization of the risk as it related to El Chiqui, not others who, by his own conclusion, were looking for the Applicants, and threatening their family members still in Honduras. ... There is no doubt that an IFA must be considered in light of the circumstances then confronting the Officer. ...

The CRA considered these documents as a request for a second review of the first decisions. [13] Ms. ... Singh’s oral and written representations and supporting documentation submitted after the first review were duly considered. ... Singh that had not been submitted before the CRA during the first reviews, and she considered these additional submissions as well. ...

An organization cannot be considered to be engaged in the production of ONC based on an isolated act. ... This aligns with the CRA’s position that a three-week period is generally representative of an organization’s activities and allows the organization to present its case. [42] The three-week news content sample considered by the CRA included 423 news reports. ... The Officer’s report found that 10 of the 423 items reviewed over a three-week period could be considered original news content. [43] The Act at subparagraph 248(1)(a)(v) requires a QCJO to be “engaged in the production of original news content.” ...

Therefore they must be considered under the principles of the solicitor-client relationship. ... the communication must be directly related to the seeking, formulating as giving of legal advice. @ B A... evidence as to what monies a solicitor holds, has received, or has paid on behalf of a client is not privileged because the handling of a client = s funds is considered to be an act, not a communication. @ [11]            I have also examined the documents in question. ... As such, and without some other evidence, it cannot be considered as a privileged communication. ...

Subsection 225.2(1) of the Income Tax Act provides as follows: SEC. 225.2 Collection in jeopardy. (1) Notwithstanding section 225.1, where it may reasonably be considered that collection of an amount assessed in respect of a taxpayer would be jeopardized by a delay in the collection thereof, and the Minister has, by notice served personally or by registered letter addressed to the taxpayer at his latest known address, so advised the taxpayer and directed the taxpayer to pay forthwith the amount assessed or any part thereof, the Minister may forthwith take any of the actions described in paragraphs 225.1(a) to (g) with respect to that amount or that part thereof. ... By virtue of section 225.2, the Minister may give a notice or direction to pay forthwith an amount assessed for tax where it may reasonably be considered by the Minister that the collection of the amount so assessed would be jeopardized by a delay in the collection thereof. ... The test of "whether it may reasonably be considered” is susceptible of being reasonably translated into the test of whether the evidence on balance of probability is sufficient to lead to the conclusion that it is more likely than not that collection would be jeopardized by delay. ...