http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/70949/index.do 
Covic v. The Queen (April 7, 2014 – 2014 TCC 105) was an application to extend the time to file an appeal under the
Canada Pension Plan. The relevant provision of the T
ax Court of Canada Rules of Procedure respecting the
Canada Pension Plan was as follows:
28.(1) Appeal to Tax Court of Canada – A person affected by a decision on an appeal to the Minister under section 27 or 27.1, or the person’s representative, may, within 90 days after the decision is communicated to the person, or within any longer time that the
Tax Court of Canada on application made to it within 90 days after the expiration of those 90 days allows, appeal from the decision to that Court in accordance with the Tax Court of Canada Act and the applicable rules of court made thereunder.
The taxpayer’s application was three days late. Unfortunately for the taxpayer the court held it had no discretion to extend relief beyond the cumulative 180 period set out in the
Rules:
[11] In accordance with these provisions and the evidence in this case, the limitation period for this application is 180 days and it starts to run from the date that the Minister’s decision is mailed, as stated in the decision. The mailing date as stated in the decision is March 21, 2013 (Exhibit C to Affidavit of Sandra Stewart).
[12] The limitation period ends 180 days later, which is September 17, 2013. Unfortunately, Mr. Covic did not make the application by this date. The application letter is dated September 19, 2013 and it bears a filed stamp of the Registry dated September 20, 2013 (Exhibit D to Affidavit of Sandra Stewart). It is clear that the application was not filed by the deadline of September 17, 2013.
[13] Since the limitation period has been missed, this application should be dismissed.
[14] Before concluding, I would comment that the result in this case is harsh. Not only was the deadline missed by a very short period, but if the legislation had provided a deadline of six months instead of 180 days, the application would have been made in time.
[15] Although the circumstances are sympathetic, there is no relief that this Court can provide. The application will be dismissed.