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The following factors will be considered when determining whether or not the Department will cancel or waive interest or penalties: (a)    whether or not the taxpayer or employer has a history of compliance with tax obligations; (b)    whether or not the taxpayer or employer has knowingly allowed a balance to exist upon which arrears in interest has accrued; (c)    whether or not the taxpayer or employer has exercised a reasonable amount of care and has not been negligent or careless in conducting their affairs under the self-assessment system; (d)      whether or not the taxpayer or employer has acted quickly to remedy any delay or omission. 10.    ... The Court had concluded that the plaintiff was in good faith and that the Department of National Revenue had waited a long time to inform the taxpayer that his farming losses would not be considered. ...

At 18, the learned judge added:      In other words, it is the teleological interpretation that will be the means of identifying the purpose underlying a specific legislative provision and the Act as a whole; and it is the purpose in question which will dictate in each case whether a strict or a liberal interpretation is appropriate and whether it is the tax department or the taxpayer which will be favoured. [9]      The plaintiff therefore submitted that s. 16 should be considered in terms of the purpose of the Act: promoting the construction industry, and thus with a liberal interpretation of that section. 4.      ... Clearly, such forms have no valves or fittings. [14]      Section 16 has never been considered by the courts at the Federal Court or Supreme Court level. ...

Irving, a Collection Officer for the Minister, can be considered a "federal board, commission or other tribunal". ... Irving fits into the definition under Section 2 does not mean that all of his statements can be considered as decision s subject to judicial review.      ...

This initial assessment was considered not properly conducted and the decision to deny the Applicant’s request was made on August 29, 2007. ... On April 6, 2009, the CRA issued a first-level decision rejecting the Applicant’s request on the ground that while heavy metal toxicity may have psychological effects, it was considered that there was no apparent correlation between any medical condition and his financial health during the period in question or his mental abilities more generally (Exhibit “B” to the Affidavit of Leslie Green).       ...

”   [20]            Specifically, the applicant submits that the Minister should have considered the amount of the penalty assessed in light of the size of the applicant’s previous assessments and its reasonable expectation that no repeat penalty would be assessed as none had been in the past ...     [28]            In my assessment, t he Minister considered all the submissions of the applicant, and reasonably concluded that these did not justify the other directors’ failure to perform their roles as directors of Nedza.  ...

Gibson denied the applicant’s request on the basis of a review of the applicant’s tax situation in relation to the reasonableness of care exercised in the administration of his affairs under the self-assessment system, and in applying the taxpayer relief provisions of the ITA, the delegate considered that Mr. ... The delegate considered the facts before him, acted in good faith and did not rely upon irrelevant or extraneous factors. ...

While the applicants make several arguments regarding the unreasonable nature of the Board's credibility determinations, only one of them need be considered by me, as, for the reasons discussed below, it is determinative and results in the Board's decision being set aside.   ... Rather, the respondent asserts that the Board’s negative credibility determination can be upheld based on some of the other factors the Board considered. ...

All things considered, to prove that this sale was not simply a sham intended to allow Mr. ... Rochon to serve twelve (12) other pharmacist clients in addition to the eight (8) clients who were part of the sale on August 2, 2003. [20]            After having carefully considered all of the evidence and arguments brought to the Court’s attention by the parties in their motion records and pleadings during the hearing, I cannot conclude that Mr. ...

In contrast, even though the right to claim compensation for the losses or damages suffered by a party to the contract as a result of the other party’s failure to execute its obligations is a right granted by suppletive law, and even though such claims are rightly considered contractual claims, they cannot be considered claims for amounts under the contract. ...

The Applicant says that if these other factors were considered, they should have been disclosed to her in order to allow her the opportunity to respond to the issue.  The CRA also should have considered the fact that the Applicant had been making payments of $400 per week to address the outstanding debt ...