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However, the decision-makers considered that the Applicants were warned in all of the letters and was advised to pay to avoid the accumulation of interest.   ... The Team Leaders considered the dates for the audit and the objections and determined that the Applicants always received their response before the timelines provided.   ... Cancelling a penalty based on an inability to pay or financial hardship would not generally be considered, unless an extraordinary circumstance prevents compliance. ...

The Tax Court of Canada decision [12]   After summarizing the relevant facts, the Judge considered the principles set out by the Supreme Court in Stewart to determine whether the appellant had a source of income. More specifically, he considered the principles set out in paragraphs 48 to 60 of that decision. ... More specifically, the appellant argues that the Judge erred in finding that her law practice could not be considered as being carried out to make a profit given the little time she devotes to it, the gross income it generates and the conduct of her practice in general. ...

A decision will be unreasonable if the BIOC are not sufficiently considered (Kanthasamy, cited above, at para 39). ... The Officer considered them but said they are “undated and some of the photos appear to have been taken at a hospital with a newborn.” ... The Applicant stated that as “none of these factors were specifically considered by the Officer in the decision. ...

The Officer then included quoted portions of paragraphs of the RPD decision that addressed credibility (RPD decision, paragraphs 4, 21, and 25). [10]   The Officer found that the risk alleged by the Applicant, that he would be at risk of harm in China because he is a Christian who attended an underground Christian house church, was the same risk considered by the RPD. ... The Federal Court of Appeal set out a non-exhaustive list of factors to be considered by a decision-maker when assessing the admissibility of new evidence, including credibility, relevance, newness, and materiality. ... Had the Officer considered the new evidence concerning schizophrenia in the context of the RPD’s credibility findings, the Officer may or may not have found that no change in the RPD’s credibility assessment was warranted. ...

She stated that she considered whether the appellant was a person able to handle properly management and maintenance of the appliance. ... Canada), [1995] 1 C.T.C. 2927, considered the provisions of section 118.3 as it pertained to the taxpayer who had a colostomy and evacuated his bowel into a bag or pouch. ... Indeed, the language of Parliament is very clear and precisely defines what is and what is not to be considered a basic activity of daily living. ...

Dyck formed her opinion by looking backward from 1975 and considered as relevant to her conclusion plans which were then in place but which did not exist in 1971. ... All were considered solely for their agricultural capability, and indeed the comparable selected by Mr. ... The Ravis study forms part of the material considered by Mr. Helmers and was appended to his appraisal report. ...

It is the settlement document dated October 24, 1983 (Exhibit A-1-5) which should be considered in determining this question. ... Continuation of Insurance: Disability — During periods of disability, an insured employee will be considered as still employed on a full-time basis, if the policyholder, acting on a basis precluding individual selection, continues that employee’s insurance. ... To what degree Constellation Life considered that a “liability” is not for me to examine — that just happens to be the word he used in the settlement. ...

The sale of an eight-acre property for $7,688 per acre in November, 1972 was considered by Mr Keenleyside the best of the nine comparable sales, notwithstanding the same property was sold for $5,625 per acre in April 1972. ... Mr Michel considered seven comparable sales. Five of these comparables were used by Mr Keenleyside. ... Mr Michel's second comparable not considered by Mr Keenleyside was the sale of 6.39 acres, which included an old home and double garage, for $54,000 or $7,910 per acre, on May 24, 1972. ...

The land in question, however, was listed as M-3A zoning and had to be considered as a non-conforming use. ... He states that the only other lot in the surrounding area was one that had fill in it but was not being used for M3 purposes and therefore had to be considered on an entirely different basis. ... He was questioned about the availability of services to the areas as having some effect and his answer was: “True, that could be a factor that might be considered but it wasn't critical’’. ...

Defendant therefore cannot be considered as having rights of ownership which would imply the right to dispose of or use the information in any legal manner it might choose. ... Royalties, which are akin to rental payments, have invariably been considered as income since they are either based on the degree of use of the right or on the duration of the use, while a lump sum payment for the absolute transfer of a right, without regard to the use to be made of it, is of its nature considered a capital payment, although it may of course be taxable as income in the hands of the recipient if it is part of that taxpayer’s regular business... ... In other words, everything is considered to be covered. This is a fundamental change from the basic scheme and concept of the previous Act which employed general language in its charging provisions. ...