The moving party, a sailing club that leases land from the City of Toronto, sought to file a late appeal of its 2017 property tax assessment.
The club argued it did not receive the notice of assessment from the City until well after the filing deadline.
The Assessment Review Board dismissed the motion, finding that while the club proved it did not receive the notice, it failed to establish a legal entitlement to receive it and failed to file the application for a late appeal within 30 days of becoming aware of the issue, as required by Rule 26(b).