Heels v. Canada (Attorney General), 2003 DTC 5712, 2003 FC 1346 (FCTD) -- summary under Subsection 220(3.1)

The Minister's decision not to grant relief from interest and penalties for the late filing of returns was not patently unreasonable given that the illness of the mother of the applicant, which formed the basis for the requested relief, did not prevent the applicant from continuing to operate her music studio, and her late-filing of returns was part of a long-established pattern that continued after the death of her mother.