Galetzka v. Canada (Minister of Customs and Revenue), 2004 DTC 6472, 2004 FC 672 -- summary under Subsection 220(3.1)

The taxpayer lived separate and apart from her husband under the same roof for economic reasons, her estranged husband did not give her any money except $400 per month for groceries, and she earned $12,000 per year. Under these circumstances, the decision of the Minister not to waive interest on the basis that she could obtain financing from her husband was patently unreasonably. The matter was referred back to the Minister for re-determination with directions that the only fair and reasonably decision was for interest and penalty to be waived upon the taxpayer paying $500 as a reasonable payment arrangement.