Watson D.J.T.C.:
The Minister’s motion, requesting a dismissal of the appeal on the grounds that no Notice of Objection was served for the 1991 and 1992 taxation years, was heard in Vancouver, British Columbia, on June 22, 1998.
The original Notice of Reassessment dated November 1, 1993, for the 1991 taxation year and the original Notice of Assessment dated November 16, 1993, for the 1992 taxation year were sent to the Appellant at the address given in her 1991 and 1992 income tax returns. No Notice of Objection was filed for these two taxation years within the limit set out in section 165 of the Income Tax Act.
Considering the circumstances, in the light of the well-established case law, the appeal is dimissed on the grounds that the Appellant failed to satisfy the conditions set out in section 169 of the Income Tax Act.
Motion allowed.
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