St-Onge,
TCJ
[ORALLY]:—I
think
I
have
to
agree
with
counsel
for
the
Minister
in
this
case.
I
have
to
look
at
this
first
delay,
the
ninety
days,
and
the
only
reason
given
by
the
taxpayer
in
this
case
is
ignorance
of
the
law.
This
is
not
an
excuse
and,
for
this
reason,
I
have
to
dismiss
the
application.
The
application
is
dismissed.
Application
dismissed.