See Also
Babakaiff v. The Queen, 2014 DTC 1012 [at at 2548], 2013 TCC 246
Woods J found that a letter from the taxpayer to CRA, indicating that his assessments were being appealed, that he was working with his...
Newfoundland Transshipment Limited v. The Queen, 2013 DTC 1111, 2013 TCC 259
After the normal reassessment period for assessing its 2002 to 2005 taxation years had passed, the taxpayer requested the Minister to reassess...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 165 - Subsection 165(1) | no obligation to reassess amended return | 86 |
Lambo v. The Queen, 2011 DTC 1236 [at at 1364], 2011 TCC 293
Little J. granted the taxpayer's s. 166.1 application. The taxpayer had filed a notice of objection within the ordinary objection period, and did...
Administrative Policy
Tax Professionals Mini Round Table - Vancouver - Q. 29 (March 1993 Access Letter, p. 110)
Discussion of criteria employed in reviewing applications under s. 166.1.
Subsection 166.1(2)
See Also
FOOi Inc. v. The King, 2023 TCC 176
The taxpayer was a Canadian-controlled private corporation that was found by MacPhee J to have filed its SR&ED claim for its taxation year ending...
Subsection 166.1(5)
Cases
Stover v. Canada (National Revenue), 2019 FC 1599
The taxpayer, who had not filed a Notice of Objection within the normal 90-day period for doing so, filed his Notice of Objection barely within...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 220 - Subsection 220(3.1) | CRA required to consider waiver of interest that accrued during a three-year delay in dealing with a late-filed Objection | 453 |
Subsection 166.1(7)
Paragraph 166.1(7)(a)
Cases
Canada (National Revenue) v. ConocoPhillips Canada Resources Corp., 2017 FCA 243
Woods JA found that s. 220(2.1) (which provides that “where any provision of this Act… requires a person to file a… document…the Minister...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 220 - Subsection 220(2.1) | CRA has no ability to use the s. 220(2.1) waiver to extend the period for filing a Notice of Objection | 336 |
| Tax Topics - Statutory Interpretation - Specific v. General Provisions | specific time limitation rule in s. 166.1 was implied exception to the general waiver rule in s. 220(2.1) | 289 |
See Also
Ntakos Estate v. The Queen, 2018 TCC 224
An accountant got the taxpayer (Anna – who at that point was mentally failing), months before her death, to file T1 adjustment requests in 2003...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 166 | reassessments at the request of a taxpayer lacking mental capacity were void | 430 |
DaSilva v. The Queen, 2018 TCC 74 (Informal Procedure)
The taxpayer's testimony, that she had not received a notice of assesssment denying her GST/HST new housing rebate until over three years...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 335 - Subsection 335(6) | failure of official to confirm that the notice of assessment was included in a batch that had been accurately processed | 312 |
| Tax Topics - Income Tax Act - Section 244 - Subsection 244(5) | taxpayer’s testimony that she did not receive a notice of assessment accepted over a CRA affidavit to the contrary | 188 |
| Tax Topics - Excise Tax Act - Section 303 - Subsection 303(7) - Paragraph 303(7)(a) | taxpayer's testimony that she had not received a notice of assessment was credible | 166 |