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Application for extension of time to object quashed for failing to meet statutory conditions precedent.
The applicant sought an extension of time to file a notice of objection regarding a new housing rebate assessment under the Excise Tax Act.
The Tax Court of Canada quashed the application because the applicant failed to meet the condition precedent of filing the application with the Court within 30 days of the Minister's refusal.
The Court emphasized that it lacks jurisdiction to consider the merits or whether the assessment was properly mailed if the conditions precedent are not met.
