Simpson J. granted the taxpayer's appeal for interest relief. The taxpayer, a single mother of three, had an annual income of $11,654. She was unable to afford to make the interest payments out of her income, and it was unreasonable in the circumstances for the Minister to insist that she use her proceeds from the sale of a rental property, liquidate her RRSP, or agree to a payment plan, in order to make those payments. These steps would have diverted resources that the taxpayer needed to cover necessities. Simpson J. stated (at para. 20):
Essentially, CRA thought that the Applicant should move from poverty to abject poverty and would not forgive her interest unless she [used the sale proceeds of the rental property to pay the interest rather than buy a trailer home]. This position was, in the circumstances of the case, utterly unreasonable.