ConocoPhillips – Federal Court of Appeal finds that a taxpayer can appeal a decision of CRA, to treat a Notice of Objection as invalid, to the Tax Court

Where a taxpayer wishes to demonstrate that its Notice of Objection in fact was filed on a timely basis because it did not receive the reassessment when alleged by CRA, the correct procedure is for it to appeal to the Tax Court for an adjudication of when the notice of reassessment was mailed.

Neal Armstrong.  Summary of Minister of National Revenue v. ConocoPhillips Canada Resources Corp under s. 169(1).