Wiegers – Tax Court finds that it has no jurisdiction to order the renewal of a settlement offer

In rejecting the taxpayers’ request for an order requiring the Minister to make a settlement offer to the taxpayers consistent with that previously made (supposedly unbeknownst to the taxpayers) to other participants in the same gifting tax shelter, MacPhee J stated:

[I]t remains clear and obvious, upon a review of the jurisdiction of the Tax Court as listed at section 171 of ITA, I cannot force either the Minister nor the Respondent to remake an expired settlement offer to an appellant.

Neal Armstrong Summary of Wiegers v. The Queen, 2019 TCC 260 under s. 171(1).