http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/97832/index.do 
Poot v. The Queen (September 30, 2014 – 2014 TCC 295) was a decision involving two appeals where it seemed that the relief sought by the taxpayers was essentially to be allowed to late file notices of objection for their 2000 taxation years:
[2] The relief that is being sought is set out in paragraph (g) of the Notices of Appeal as follows:
[…] to review the decision of the Chief of Appeals and direct the Canada Revenue Agency to (i) allow the Notice of Objection and (ii) review the tax-payer relief request for interest and penalties;
[3] The only issue that is appropriate for this Court to consider is whether an extension of time should be granted to file notices of objection to reassessments for the 2000 taxation year. The Court may grant this relief pursuant to subsection 166.2(1) of the Income Tax Act, provided that certain legislative requirements have been satisfied.
The court concluded that the underlying application to the Minister was fatally flawed because it should have been filed on or before October 4, 2008:
[9] Paragraph 166.2(5)(a) requires that an application be made to the Minister for an extension of time within a deadline, which in this case is October 4, 2008. Unfortunately for the applicants, there is no evidence that this was done.
[10] Although the applicants and their accountant engaged in correspondence with the Canada Revenue Agency (CRA) before the October 4, 2008 deadline, none of the correspondence can reasonably be viewed as applications to extend time, or as notices of objection.
It is not clear from the decision why October 4, 2008 is the relevant date; there is no discussion of when the reassessments were issued.
Although one of the appellants did write to CRA prior to October 4, 2008 asking for relief from interest and penalties the court was not prepared to construe this as a notice of objection or an application to extend the time to file a notice of objection:
[15] A subsequent letter was sent by Mr. Poot and addressed to “to whom it may concern”. The letter was dated November 3, 2007 and requested a waiver of interest and penalties.
[16] This letter does not purport to be a notice of objection and it would not be appropriate to consider that it is. Based on the letter and the testimony of Mr. Poot, it appears that the letter was intended to be an application for taxpayer relief for a waiver of interest and penalties on equitable grounds. This is not a notice of objection.
[17] I have concluded that the applicants have not satisfied the requirement set out in s. 166.2(5)(a) and therefore the applications must be dismissed.
The appellants here were represented by an agent, not by counsel, and the overall tenor of the decision suggests that they were not overly familiar with tax procedure. In a somewhat unusual portion of the decision the court wrote:
[8] In this case, the agent for the applicants appears to acknowledge that the requirement in s. 166.2(5)(a) has not been satisfied.
“Appears to acknowledge” is a difficult phrase to interpret.
It is possible that another judge would have reached a different interpretation of the November 3, 2007 letter and construed it as a either a notice of objection or an extension request; unfortunately the underlying facts remain somewhat opaque.