Taylor
J.T.C.C.
(orally):—
Thank
you
kindly.
These
are
just
one
or
two
short
judgments
that
I
will
read
into
the
record
before
we
start
with
today’s
cases.
Carol
and
Keith
Shewan.
These
are
applications
for
extension
of
time
within
which
to
file
Notices
of
Objection
for
the
taxation
years
1991
and
1992
for
Carol
Shewan
and
for
the
year
1992
for
Keith
Shewan,
heard
on
common
evidence.
The
basic
facts
are
recorded
in
the
Reply
to
an
application
for
extension
of
time
filed
by
the
respondent
on
July
11,
1995.
The
details
of
which
apply
to
both
appellants
as
follows:
The
re-assessments
at
issue
were
dated
January
19,
1994;
the
Notices
of
Objection
were
dated
October
20,
194;
the
refusal
by
the
respondent
was
dated
December
23,
1994;
the
instant
applications
were
dated
April
10,
1995.
The
period
of
time
between
December
23,
1994
and
April
10,
1995
is
longer
than
the
90
days
permitted
under
subsection
166.2(1)
of
the
Income
Tax
Act,
R.S.C.
1985
(5th
Supp.),
c.
1
(the
“Act”).
I
would
refer
to
the
case
of
McGowan
v.
R.
(sub
nom.
McGowan
v.
The
Queen),
[1995]
2
C.T.C.
18,
95
D.T.C.
5337
(F.C.A.).
The
applications
are
dismissed.
Applications
dismissed.
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