The applicant brought a motion for reconsideration of an order dismissing her application to extend the time to file appeals for the 2007, 2010, and 2011 taxation years.
The applicant argued the Court was unaware of an earlier attempt to file a notice of appeal.
The Tax Court of Canada dismissed the motion, finding that the doctrine of functus officio applied and that the narrow exceptions under Rule 168 were not met, as the original decision accorded with the reasons and no matter was accidentally overlooked.
