John
B
Goetz:—This
is
an
application
by
the
taxpayer
George
Akis
Ventiris
for
an
extension
of
time
in
which
to
file
a
notice
of
appeal
in
respect
of
the
1975
and
1976
taxation
years.
Mr
Ventiris
left
the
Province
of
British
Columbia
in
April
1978
without
a
forwarding
address
and
arrived
in
the
Province
of
Manitoba
about
that
time.
To
that
point
in
time
he
had
not
received
an
assessment
from
the
Department
of
National
Revenue.
An
assessment
was
issued
in
August
1978
and
from
the
beginning
of
November
1978,
the
taxpayer
was
in
contact
with
the
Winnipeg
Tax
Office
with
respect
to
his
new
address
and
his
1977
income
tax
return.
By
letter
dated
May
14,
1979,
he
wrote
to
the
Registrar
of
the
Tax
Review
Board,
asking
for
permission
to
appeal
and
wherein
he
stated
that
since
the
beginning
of
1979
he
had
been
negotiating
with
the
Winnipeg
Office
in
an
attempt
to
arrive
at
a
fair
and
proper
assessment
(in
his
view).
This
letter
was
not
received
by
the
Tax
Review
Board
until
January
7,
1980.
Subsection
165(1)
of
the
Act
reads
as
follows:
A
taxpayer
who
objects
to
an
assessment
under
this
Part
may,
within
90
days
from
the
day
of
mailing
of
the
notice
of
assessment,
serve
on
the
Minister
a
notice
of
objection
in
duplicate
in
prescribed
form
setting
out
the
reasons
for
the
objection
and
all
relevant
facts.
If
the
letter
dated
May
14,
1979
asking
for
permission
to
appeal
had
been
properly
addressed
to
the
Minister
as
required
by
section
165,
the
taxpayer
might
have
been
apprised
of
the
fact
that
he
could
have
applied
for
an
extension
of
time
to
file
a
notice
of
objection
being
one
year
from
assessment
of
August
1978.
However,
even
considering
the
vicissitudes
of
the
Canadian
postal
service,
l
cannot
but
reach
the
conclusion
that
the
said
letter
of
May
14,
1979
was
not
mailed
by
the
taxpayer
until
after
the
lapse
of
one
year
from
the
assessment
of
August
1978.
There
being
no
proper
notice
of
objection
served
on
the
Minister,
I
have
no
jurisdiction
to
deal
with
an
appeal
or
an
application
for
an
extension
of
time
within
which
to
appeal.
The
application
is
dismissed.
Application
dismissed.
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