http://decision.tcc-cci.gc.ca/site/tcc-cci/decisions/en/item/64471/index.do
Hanson v. The Queen[1] (October 25, 2013) involved an application to extend the time to file a notice of objection. The case concerned a tax arrangement known as “Global Learning Donation Program”.
[4] The circumstances of this case are sympathetic. Mr. Hanson was dealing with very difficult family circumstances during part of the time period at issue. In addition, he and his spouse testified that they had signed notices of objection and had received assurances from the representative of Global Learning that they would be filed. There is no record of the objections having been sent and the representative appears to be refusing to speak to Mr. Hanson. It appears that the Hansons are being left out to dry by the representative.
Unfortunately for the taxpayer more than one year had passed since the date for filing a notice of objection and the court had no jurisdiction to permit a late-filed notice of objection.
[1] 2013 TCC 341.