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In her report and worksheet, she considered the following factors and recommended that the Applicant 's first fairness request be denied: (a)       The Applicant has a history of late-filing returns from 1996 to 1999; (b)       There were no extenuating circumstances beyond the Applicant 's control. ... She considered the following factors and recommended that the Applicant 's second fairness request be denied: (a)       There were no unusual circumstances preventing the Applicant from filing his returns on time; (b)       He had a poor filing history before the years in issue; and (c)       He did not provide any additional information for the second review. [10]            By letter dated February 6, 2002, Ms. ... During the hearing, I informed the Applicant that as it was not part of the material considered by the decision maker, the said letter should not be considered. [24]            The Minister had to consider whether the occurrences submitted by the Applicant amounted to extraordinary circumstances resulting in his failure to properly and correctly report his taxable personal income for 1998, 1999, and 2000. [25]            Ms. ...

The Applicant set out her circumstances in a number of letters to the Minister and their contents were considered and a response was given. [7]                The Guidelines suggest that what should be considered are the following: whether, pursuant to s. 5, there are extraordinary circumstances; whether, pursuant to s. 6, the interest or penalty was primarily because of the actions of the Minister; or whether, pursuant to s. 7, there is an inability to pay. [8]                In addition to these considerations, s. 10 of the relevant Information Circular sets out a number of factors that will be considered when reaching a conclusion. ... Whether this has occurred is one of the factors to be considered as set out in s. 10 of the Guidelines when the Minister exercises his discretion. ... [14]            The Minister considered the Guidelines and concluded that the interest would not be waived or cancelled in these circumstances. ...

The Minister considered the requests pursuant to subsection 152(4.2) of the Act. ... These adjustments are consistent with amounts that were allowed in previous years and considered reasonable ... Considered the amounts reduced or disallowed for reasonableness. i.          ...

Taxpayers are generally considered to be responsible for errors made by third parties acting on their behalf for income tax matters. ... inability to pay or financial hardship   We have carefully considered the facts in your record. ... Third parties who provide incorrect advice or who make errors are generally considered to be responsible to their client. ...

A different CRA Officer considered this request. The second-level request was denied on December 20, 2005. ... Preliminary Issue [16]            As a preliminary issue, the Respondent argues that only the evidence that was before the decision-maker should be considered in this application. ... It is well accepted that only the information that was before the decision-maker can be considered by a reviewing court on judicial review. ...

Having considered the RAD’s findings, the evidence before the panel and the applicable law, I can find no basis for overturning the RAD Decision. ... It concluded that, when considered separately or together, these events did not rise to the level of persecution. ... Here, the RAD carefully considered the evidence submitted by the Applicants and provided detailed reasons that allow the Court to understand its reasoning. ...

The Decision under Review [9]   The Officer considered the relevant evidence and factors. ... Shah’s submission, the Officer considered the evidence submitted to support the close relationship between Mr. ... The Officer considered the factors set out in the Guidelines to the extent that they applied. ...

The ID member considered the defence, but concluded the Respondent had failed to establish all elements of the prevailing test for duress at that time. [6]   The Respondent (then Applicant) applied to the Federal Court for judicial review of the ID decision. ... Is duress, a factor properly considered by the Minister personally for Ministerial relief, also a factor that the ID and IAD may consider in assessing inadmissibility pursuant to s. 37(1)(a)? ... If considered as a factor to negate a mental clement what is the mental element that would be negated? ...

- Are there children directly implicated in the application whose best interests should be considered?- ... [16]   The Program Manager first considered the severity of the Applicant’s IRPA violation.   ... The Applicant appears to be arguing that the Program Manager should have considered the Applicant’s value to Ms. ...

The funds were not contemporaneously deposited to an account at a financial institution. [36] In my view, the record demonstrates that the Officer considered all of the documents submitted by the Applicant. ... The Officer considered: a) That the Applicant claimed to be paid in cash and did not deposit any amount in a bank account; b) That the Applicant only had invoices that she prepared herself as a proof of revenue. ... Having considered the factors listed in sub rule 400(3) of the Rules, as well as the calculation made by the respondent, and all other circumstances of this case, I find that no award for costs is warranted in this matter. ...