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The most relevant portion of the decision reads as follows: A thorough review of the account has been completed and I have considered all comments in your representative’s letters. ...   [11]            In applying the standard of review of reasonableness to the Minister’s delegate’s decision, the respondent submitted that the Minister’s delegate considered all the facts and circumstances of the case and decided that a refund would not have been made if the applicant’s request had been filed during the normal assessing process. ... The respondent submitted that the Minister’s delegate considered all the evidence and rendered a decision that was reasonable in light of the facts of the case ...

The Applicant’s request and reasons were considered and the response of the officials was obtained. ... The Assistant Director obviously considered both sides of the argument on this issue and, given the Applicant’s own evidence concerning its financial situation, his Decision seems reasonable. 2.                   ... The Assistant Director considered the request and the reasons advanced by the Applicant. ...

  [2]                Having carefully considered the evidence in the record, as well as the written submissions and oral arguments of the parties, I find that this application for judicial review must be dismissed. ...   [15]            Since Compu-Finder had considered the applicant to be self-employed worker from 2002 to June 2005 and therefore had not made deductions at source on the payments it was making for his services, Ms.  ... Compu-Finder never considered the applicant to be one of its employees during the 2004 taxation year and the first six months of 2005; otherwise, it would have been required to withhold amounts for tax at source. ...

The Jurisdiction of a Citizenship Judge to Re-test [14]            Subsection 5(1)(e) of the Citizenship Act requires an applicant for Canadian citizenship to have an adequate knowledge of Canada: Grant of citizenship Attribution de la citoyenneté 5. (1) The Minister shall grant citizenship to any person who 5. (1) Le ministre attribue la citoyenneté à toute personne qui, à la fois: […] […] (e) has an adequate knowledge of Canada and of the responsibilities and privileges of citizenship; e) a une connaissance suffisante du Canada et des responsabilités et avantages conférés par la citoyenneté; [15]            Subsection 14(1) provides that a citizenship application “shall be considered by a citizenship judge who shall […] determine whether or not the person who made the application meets the requirements of this Act and the regulations”.   ... Characteristics of Canada other than those referred to in paragraphs (a) to (d). [18]            Subsection 15(2) states that a person is considered to have “an adequate knowledge of the responsibilities and privileges of citizenship if they demonstrate, based on their responses to questions prepared by the Minister, that they have a general understanding of” the following subjects: a.               ... The interests of the applicant in obtaining citizenship are far removed from those considered in the jurisprudence with respect to section 7; Tabingo v Canada (Minister of Citizenship and Immigration), 2013 FC 377 affd, Shahid v Canada (Citizenship and Immigration), 2014 FCA 191. [32]            The applicant argues that section 15 is engaged because she is discriminated against as a woman in Canada seeking citizenship while her husband remains in China.   ...

While the appeal to the learned trial Judge 5 concerned the tax imposed upon the appellant in regard to all three of his activities and the appeal was dismissed, the reasons for judgment make it clear that in coming to the conclusion that the appellant was carrying on a business he had considered only the activities of the appellant in connection with the investment of his moneys. ... From this I infer that the learned trial Judge considered that the failure of the appellant to produce further evidence as to the manner in which he had carried on these activities in two or three of the years preceding and following 1940 justified the inference that he was selling securities at a profit and replacing them by others at lower prices, in the hope of disposing of them later at a profit, and that accordingly he was not merely investing his moneys in the manner indicated in the passage first above quoted. ... Under these circumstances, it can scarcely be suggested that the appellant intentionally held back any facts from the Court: if particulars of the investments made in these other years had been considered of importance the information could readily have been obtained on the cross-examination of the appellant. ...

During the course of the trial, the President intimated that he considered this decision inapplicable, and it would appear from his reasons for judgment that he adhered to that view. ... In the present case, the Minister has considered and determined the two matters mentioned in section 98 of the Special War Revenue Act. ... Even with these assumptions, we cannot be aware of all the reasons that [Page 186] moved the Minister and, in any event, his jurisdiction under section 98 was dependent only upon his judgment that the goods were sold at a price which was less,—not, be it noted, less than what would be a fair price commercially or in view of competition or the lack of it,—but less than what he considered was the fair price on which the taxes should be imposed. ...

It stated that senior government representatives had reviewed the original KPMG Study and its subsequent enhancement and considered "the study flawed and its findings to be unreliable" (Appeal Book at 321). ... Its submissions were considered by Revenue Canada in making its determination on the proposal. ... They considered the KPMG Study and its subsequent enhancement "flawed and its findings unreliable". ...

Accordingly, the opposing parties could not oppose the seizure of the property, since they cannot be considered the owners of that property. ... So, adopting mutatis mutandis the reasons expressed in paragraphs 24 to 30, the opposing parties could not oppose the seizure of the property, given that they cannot be considered the owners of this property. ... They cannot therefore be considered the owners of this property as well. ...

  [8]                Rolland Bastien considered the income from the operation of his business, Les Industries Bastien enr., to be property exempt from taxation; this income was neither audited by the Canada Revenue Agency, nor was it taxed. ...   [12]            Justice Angers highlighted that in Recalma, above, this Court restated the principles enunciated in Williams, above, and identified four connecting factors to be considered in determining the situs of investment income: (1) the investment income’s connection to the reserve; (2) the benefit of the investment income to the traditional Native way of life; (3) the potential danger of the erosion of Native property; and (4) the extent to which the investment income may be considered as being derived from economic mainstream activity. ... The substantive portion of the reasoning in this case was set forth by Justice Linden at paragraph 11: [11]      So too, where investment income is at issue, it must be viewed in relation to its connection to the Reserve, its benefit to the traditional Native way of life, the potential danger to the erosion of Native property and the extent to which it may be considered as being derived from economic mainstream activity. ...

]   [13]            Finally, the judge considered the remuneration paid to the appellants, pointing out that the appellants also bore the burden of proof in that respect. ... The judge also considered this particular argument of the appellants.   [14]            On the basis of the evidence before him, the judge estimated the number of hours worked by each of the appellants. ... Although it was not specifically mentioned, I believe that this was a circumstance that, as it should, was considered by our Court ...