The test to be applied under section 225.2(2) is set out in Danielson v. Deputy Attorney General of Canada et al, [1986] 2 D.T.C. 380 (F.C.T.D.) at page 381: ...the mere suspicion or concern that delay may jeopardize collection would not be sufficient per se. The test of "whether it may reasonably be considered" is susceptible of being reasonably translated into the test of whether the evidence on balance of probability is sufficient to lead to the conclusion that it is more likely than not that collection would be jeopardized by delay. ... ... In my opinion, the issue is not whether the collection per se is in jeopardy, but rather whether the actual jeopardy arises from the likely delay in the collection thereof. BACKGROUND
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