The applicant applied for an extension of time to file a notice of objection to notices of assessment for the 2020 and 2021 taxation years.
The Minister denied the request because it was made beyond the one-year and 90-day statutory deadline.
The applicant argued it never received the notices of assessment.
The Tax Court of Canada found that the Minister proved on a balance of probabilities that the notices were mailed to the applicant's address on file on September 13, 2022.
Consequently, the deadline to apply for an extension was December 12, 2023.
As the application was filed in January 2024, the Court lacked jurisdiction to grant the extension.
The application was denied.
