Bremer v. Canada (Attorney General), 2006 DTC 6125, 2006 FC 91 -- summary under Subsection 220(3.1)

After indicating (following Lanno v. The Queen, 2005 DTC 5245, 2005 FCA 153) that the applicable standard of review was one of reasonableness, O'Keefe J. went on to find that the relevant decision makers, in reviewing an application of the taxpayer for relief from additional late filing penalties of 1% per month in a situation where he had paid the amount of tax owing by him almost immediately after the tax filing deadline, but had not filed his tax return until five months later, had committed a reviewable error by proceeding on the basis that an amount had been outstanding until the date of filing the return. The matter was referred to a different decision-maker for re-determination.