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Robert Duncan, [2] Associate Chief Justice Jerome wrote at page 727: In Satellite Earth, MacKay J. reviewed the factors to be considered by a court on a s. 225.2(8) review of a jeopardy collection order.  ...

Statutory Provisions:      These provisions, coming out of any number of amendments to cope with what the defendant Crown considered loop-holes, now read like something which resembles a Marseilles bouillabaisse.      ...

  [18] Also note that the fact that the applicants already had several remedies since they came to Canada may be considered in the assessment of the balance of convenience (Selliah v. ...

The Chief of Appeals reviewed the whole file de novo; he considered new evidence brought to his attention. ...

Canada, the Federal Court defined the test to be applied when issuing an authorization under subsection 225.2(2) of the ITA as follows:  (…) 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 jeopardised by delay.   ...

Turner’s decision and concluded that the Applicant’s claim had been fairly considered. ...

  [16] With no challenge to the disbursements claimed in the bill of costs and considering their justification in John White’s affidavit, said disbursements are considered to be justified and to be expenses necessary for the conduct of this matter. ...

I have considered the submissions of the parties and I do not believe that an award of costs on a solicitor and client basis is justified in this case. ...

Therefore, I am of the view that it will be better to leave for the judge who must rule on the application for judicial review the task of deciding whether to grant the relief sought by the applicant, subject to possible limitation of its scope if the applicant considers that appropriate. [19]            It must therefore be considered that now, at least at the interlocutory stage, there is res judicata with respect to the non-striking of this application for an injunction. ...

  [14]            I have also considered the contents of the respondent’s letter to the Court dated April 9, 2007 ...