What is the standard of review applicable to a Minister's Exercise under subsection 220(3.1) of the Income Tax Act?

Canada (Federal), Canada

The following excerpt is from Osborne v. Canada (Attorney General), 2010 FC 673 (CanLII):

The standard of review applicable to the exercise of the Minister's discretion under subsection 220(3.1) of the Income Tax Act is reasonableness: Telfer v. Canada (Revenue Agency), 2009 FCA 23, [2009] F.C.J. No. 71, at para. 2.

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