The Federal Court usually upholds CRA’s decisions but not in this case.
 The reasonableness of the decision is determined based on the record – i.e. the information available to the decision-maker – and not on information provided after the fact.
 … “In other words, if the reasons allow the reviewing court to understand why the tribunal made its decision and permit it to determine whether the conclusion is within the range of acceptable outcomes, the Dunsmuir criteria are met.”
 The corollary is also true; if the reasons do not allow the Court to understand why the decision-maker decided as it did and do not permit the Court to determine whether the decision is within the range of acceptable outcomes, the Dunsmuir criteria are not met and the decision cannot be said to be reasonable.
 The Appeals Officer concluded that the applicants’ conduct was fraudulent. However, her reasons do not show a full appreciation of the notion of fraud or any real assessment of whether the applicants’ conduct was fraudulent. ... An allegation of fraud is very serious. The applicants’ conduct may have been fraud, if indeed there was no authorization at all to access the taxpayer’s information. However, if the applicants had an authorization in 2009 and were not advised of revocation of that authorization, and acted on the honest belief that they remained authorized to access the taxpayer’s information, the fact that they did so for reasons other than tax reasons may render their conduct disreputable, but not likely fraudulent.
 The applicants’ long history of good compliance with CRA is also relevant, as is the isolated nature of this conduct within a long history of good compliance. The Appeals Officer did not appear to consider that these factors could be taken into account; rather, she appears to have determined that the conduct was fraud and was serious, and that no factor could mitigate the nature or seriousness of this conduct.
 The Appeals Officer also failed to consider the impact of the loss of these privileges on the applicants. Although the applicants made more extensive submissions to the Court regarding the extent of the harm, they did note the impact of the loss of these privileges in their request for the Administrative Review. Based on her experience, the Appeals Officer would have been aware of the consequences. However, there is no indication that she took these into account other than to note that the applicants stated that they did not want to lose their privileges.
 In addition, the Memo to File does not reveal the extent of the Appeals Officer’s consideration or review of the decisions taken by Lori Hindy (TRIS), Frank Lemieux (the EFILE Helpdesk), the Security Incident Report or the incomplete National Issues Sheet – all of which reiterated basically the same information and conclusions – or whether she simply accepted these decisions as established facts and focussed on whether the proper processes were followed, rather than whether they were justified.
 The Appeals Officer’s Report on Administrative Review also failed to provide all the relevant factors to the Chief of Appeals. The Report states only the applicant’s position – that he did not believe the conduct to be fraudulent and that he was otherwise compliant – and does not indicate any assessment of this information.
 The decision to suspend the applicants’ EFILE and SEND privileges is not reasonable. The reasons and the record do not provide sufficient justification for the decision.
See Saber & Sone Group v. Canada (National Revenue), 2014 FC 1119 (Kane)