Subsection 166.2(1) - Extension of time by Tax Court
Cases
McGowan v. The Queen, 95 D.T.C 5337, [1996] 2 CTC 18 (FCA)
The Tax Court judge did not err in quashing an application for extension of time to file a Notice of Objection. The taxpayer had not applied to...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(15) | 22 |
Bordieri v. The Queen, 95 DTC 5243, [1995] 2 CTC 15 (FCA)
The taxpayer's accountant gave an application under s. 166.2(1) to Purolator Courier Service within the 90-day period referred to in s. 166.2(1)....
See Also
Brando v. The Queen, 2013 DTC 975, 2013 TCC 223
In rejecting the taxpayer's position that she had not received a notice of reassessment, V.A. Miller stated (at para. 11):
CRA cannot change a...
Haight v. The Queen, 2000 DTC 2571 (TCC)
In finding that the word "shall" in s. 166.1(2) was directory rather than mandatory (so that a letter to the Tax Services Office that did not...
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| Tax Topics - Statutory Interpretation - Interpretation Act - Section 11 | 113 |
Carlson v. The Queen, 2000 DTC 2556 (TCC)
The taxpayer, who was poorly educated, received a transfer of registered title (but not beneficial ownership) of property from an individual with...
Subsection 166.2(5) - When application to be granted
See Also
Air Canada v. ARQ, 2016 QCCA 710
The lawyer acting for Air Canada in a tax dispute with ARQ was copied on a letter to Air Canada indicating that ARQ would be reassessing in a...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) | ARQ obligated to copy a lawyer, who was its contact on a tax dispute, with its further reassessment | 482 |
Hanson v. The Queen, 2014 DTC 1003 [at at 2515], 2013 TCC 341
Woods J found that the taxpayer's family circumstances were not enough to grant an extension to file a notice of objection relating to the denial...
DouangChanh v. The Queen, 2013 DTC 243 [at at 1335], 2013 TCC 320
While the taxpayer's file for 2007 was on hold, pending the determination of a question in common with other taxpayers, the taxpayer submitted a...
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| Tax Topics - Income Tax Act - Section 152 - Subsection 152(4.2) | T1 Adjustment Request presumed not to be s. 152(4.2) application if such application would needlessly extinguish right to appeal | 299 |
Palubjak v. The Queen, 2013 DTC 1232 [at at 1272], 2013 TCC 285
Woods J confirmed that the taxpayer's failure to apply in time for an extension to file a Notice of Objection meant that her appeal must fail. ...
Morris v. R., 97 DTC 1394, [1998] 1 CTC 2479 (TCC)
The taxpayer, who did not have any intention to object to his reassessment until, following the expiration of the 90-day period, he learned of the...
D'Arcy v. The Queen, [1995] 2 CTC 2027 (TCC)
Shortly after the expiry of the deadline for objecting to a reassessment that included alimony in her income, the taxpayer learned of the decision...
Paragraph 166.2(5)(a)
See Also
Ihama-Anthony v. The Queen, 2018 TCC 262
Sommerfeldt J found that a fax sent by the taxpayer to CRA could have qualified as notices of objection even though it may have been sent before...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) | objection can be made after the proposal letter and before the notice of reassessment – but must state “I object” | 353 |
Paragraph 166.2(5)(b)
See Also
Richard A. Bureau Barrister & Solicitor Incorporated v. The Queen, 2020 TCC 119
In granting an extension for an incorporated lawyer to appeal HST assessments to the Tax Court, Russell J accepted the testimony of the lawyer...
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|---|---|---|
| Tax Topics - Excise Tax Act - Section 305 - Subsection 305(5) - Paragraph 305(5)(b) | application granted based on registrant awaiting ITA assessments | 186 |