Taylor,
T.C.J.:—This
is
an
application
for
an
extension
of
time
within
which
to
file
a
notice
of
objection
against
an
income
tax
assessment
for
the
taxation
year
1982.
The
hearing
was
in
Edmonton,
Alberta
on
January
12,
1988.
The
application
to
the
Registrar,
Tax
Court
of
Canada
was
dated
September
14,
1987,
and
read:
I
am
hereby
requesting
an
extension
of
time
to
file
this
Notice
of
Objection.
This
document
was
not
submitted
within
the
prescribed
time
limit
as
calculation
of
that
period
was
based
in
months
rather
than
days.
This
resulted
in
a
miscalculation
by
one
or
two
days.
Please
accept
my
apologies
for
this
error.
I
thought
that
I
was
acting
within
the
prescribed
term.
I
would
ask
that
an
extension
of
time
to
file
be
considered
under
this
circumstance.
If
so
granted,
there
are
further
details
that
I
would
like
to
submit
pertaining
to
this
Notice
of
Objection.
A
major
illness,
experienced
last
fall,
has
prevented
me
from
responding
to
this
appeal
procedure
prior
to
this
time.
Attached
to
that
application
was
a
copy
of
the
notice
of
objection
dated
September
14,
1986
filed
with
the
Department
of
National
Revenue.
The
assessment
notice
in
issue
was
dated
June
17,
1986.
The
above-noted
notice
of
objection
read
in
the
body
thereof:
I
feel
that
I
am
entitled
to
the
Alberta
Renter
Assistance
Credit.
I
have
been
receiving
this
benefit
in
all
previous
taxation
years
and
was
not
advised
of
any
changes
pertaining
to
this
matter.
I
therefore
request
that
the
Alberta
Renter
Assistance
Credit
be
allowed
on
my
1982
tax
return.
I
would
further
request
that
this
credit
be
allowed
on
my
1983,
1984
and
1985
tax
returns
as
these
have
not
been
filed
as
yet.
I
anxiously
await
instruction.
At
the
commencement
of
the
hearing,
the
Court
established
with
the
applicant
that
the
only
possible
matter
with
which
the
Court
could
deal
would
be
the
taxation
year
1982,
and
not
the
other
years
referenced.
The
question
of
the
jurisdictional
competence
of
the
Tax
Court
of
Canada
to
deal
with
this
application
—
because
it
arose
out
of
a
disallowed
Alberta
Renter
Assistance
Credit
—
was
raised
with
counsel
for
the
respondent.
Counsel
relied
upon
the
clauses
in
the
Canadian
Income
Tax
Act
dealing
with
Federal
Provincial
Fiscal
Arrangements,
particularly
those
having
reference
to
collection
of
tax
by
the
federal
authorities.
Leaving
aside
this
question
of
jurisdiction
for
a
moment,
the
Court
heard
the
comments
on
the
merits
of
her
application
put
forward
by
Mrs.
Acorn,
and
those
considered
pertinent
by
counsel
for
the
Minister,
and
then
the
Court
reserved
its
decision.
Having
reviewed
the
comments
of
counsel
for
the
respondent,
and
having
examined
the
relevant
legislation,
it
is
my
view
that
this
Court
does
not
have
the
authority
to
determine
the
issue
brought
forward
by
the
applicant.
Reference
might
be
made
by
the
applicant
to
the
appeal
procedures
available
with
regard
to
such
matters
falling
exclusively
within
the
jurisdiction
of
the
Province
of
Alberta.
The
application
to
the
Tax
Court
is
quashed.
Application
quashed.
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