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This includes considering and weighing all relevant circumstances, including those enumerated in the Rules which are relevant in the particular circumstances of the case.   5)      The acts of a party and events prior to the commencement of the legal proceeding may, in appropriate circumstances, be considered in awarding costs.   6)      The successful party’s actual costs may be considered and taken to account in appropriate cases. ... It appears that it can only be considered to have been intentionally deceitful. ...   [17]         However, it is not entirely clear to me that CRA’s misleading, incorrect and deceptive communications with the Martins warrant an award of solicitor/client costs, even though they would surely be considered reprehensible, scandalous and outrageous to the Canadian taxpayers CRA serves. ...

In reaching this conclusion, I considered, among others, the following factors: (a)   At the time, Sylvain Doucet had financial difficulties to the extent that he thought it was necessary to borrow $5,000 from his parents. ... The work performed does not justify the expense related to the appellant's duties, even if Sylvain Doucet were considered to have 195 clients instead of 80 or 100. (b) When the appellant's duties are considered, there is only a small amount of work to be done for the bookkeeping. ...

They submit that all such conduct was already considered by the Court at that hearing and thus that the Respondent is estopped from raising it again in this motion. [38]         There is no merit to this position. First, it is not clear to me on the record whether the Court even considered on April 3, 2012 whether the Appellants’ appeals should be dismissed. More importantly, even if the Court had considered that issue, the legal question that would have been considered was whether the Appellants’ conduct up to April 3, 2012 was sufficient to warrant a dismissal. ...

    [19]         Employment which is not held under an express or implied contract of service is not considered pensionable employment. ... As noted in Royal Winnipeg Ballet at para. 64, the relevant factors must be considered “in the light of” the parties' intent. ... Conversely, if he did not “ordinarily” report for work in Canada, the time spent in Canada working for the Appellant will not be considered pensionable employment in Canada ...

Cooke, when considered in conjunction with the services provided by Mr.  ... The fact that the appellants' son was a tenant of the Mississauga property is considered in the context of determining whether the property was used to make a profit and thus whether it was a source of income earned from a business or property. ... Thus, where the nature of a taxpayer's venture contains elements which suggest that it could be considered a hobby or other personal pursuit, but the venture is undertaken in a sufficiently commercial manner, the venture will be considered a source of income for the purposes of the Act ...

I hope this can be taken into account and that my interest and penalty charges will be re-considered. ... We have also considered whether you acted quickly to remedy any delay.  ... We have considered the above facts and have determined that the application of the late-filing penalties against the 2000, 2001 and 2002 T1 return was correct.  ...

Canada (Minister of Citizenship and Immigration) (2004), 257 F.T.R. 143, 2004 FC 1275). [19]             In this case, the applicant is unable to indicate what other criteria, if any, the immigration officer should have considered in addition to or in the place of the criteria found in the guidelines. ... The decision to grant a visa exemption is a discretionary decision and the immigration officer considered all relevant factors, including the issue of the best interest of any child affected by the decision. ... The officer’s reasons for decision show that she considered all the evidence. [23]             It is true that the applicant submitted two letters from her employer that mention that the family considered her to be a member of their family, but her employer did not elaborate on the effect that the applicant’s departure would have on their two children. ...

Had the delegate considered these to be true prerequisites, the request would not have been processed. [20]            I am satisfied on the basis of the Minister's delegate's reasons that the Minister's delegate did have regard to the absence of properly signed elections and properly identified payments when assessing the whole of the request on its merits. ... It referred only to the failure to identify payments made as relating to late filed elections. [30]            Even if I am wrong in my conclusion, and the Minister's delegate ought not to have considered these factors, I do not consider these findings to have been material to the decision. ... Given the express statement in the refusal letter that it listed the reasons for the decision, the Minister's delegate's decision should, in my view, be considered on the basis of the reasons given at the time by the delegate. [37]            As to whether it was patently unreasonable for the Minister's delegate to conclude that the filing errors were attributable to negligence or carelessness, the estate freeze and thaw transactions constituted relatively sophisticated tax planning which was not properly completed. ...

(Orally)                              6       1         of the ministerial delegate state:       2              "I have noted your comments about the interest       3              and late filing penalty, also, I have carefully       4              considered the facts of the case and your       5              submission    [sic] as    they relate    to the       6              applicable legislation.    ... (Orally)                              7       1              thanked us for taking the time to listen and,       2              therefore, no reply was considered warranted.       3              However, this letter did not indicate the       4              accounting treatment of the bad debt, i.e. was       5              the bad debt included in revenue previously.       6              The circumstances surrounding the accounting       7              treatment of the bad debt and the required       8              adjustments only came to light during the       9               course of our audit. ... However, it is for      24         the Minister to make such a determination.      25              Here, it is clear that the Director considered all                 LAYDEN-STEVENSON, J. ...

This information was received from an officer of the debtor, Jo-Ann Mauro, and was considered to be reliable ... I am also of the view that this evidence coupled with the evidence reviewed above and considered by Martineau J. in the ex parte hearing, is sufficient to establish on a balance of probabilities that the collection was jeopardized by the delay. I give particular weight to the evidence of the history of non-compliance by current and/or former directors of the applicant with respect to information requests and duties imposed by the Act, [19]            I have carefully considered the submissions of the applicant with respect to the high standard of disclosure to the Court that is required on ex parte applications. ...