http://decision.tcc-cci.gc.ca/site/tcc-cci/decisions/en/item/66638/index.do 
Yarmoloy v. The Queen[1] (January 24, 2014) involved an application to extend the time to file a Notice of Appeal for the taxpayer’s 2007 taxation year. The original notice of reassessment was dated September 23, 2010 but this was replaced by a notice of reassessment dated July 3, 2012 which had been issued in response to a T1 Adjustment Request filed by the taxpayer on March 1, 2012.
The court dismissed the appeal for want of evidence:
[11] The assessment for 2007 issued on July 3, 2012 therefore nullified the earlier assessment of September 23, 2010. The September 23, 2010 assessment no longer existed. Only the reassessment of July 3, 2012 was before me. The bulk of the evidence I heard from Mr. Yarmoloy and Mr. Richmond concerned facts relating to the non receipt of the notice of confirmation of the September 23, 2010 assessment.
[12] At the end of the hearing of this application I informed the parties that Mr. Yarmaloy would have until January 15, 2014 to provide me with any case law to support their position. I did receive copies of three reported cases, none of which I find to be on point. Mr. Richmond notified me in the covering letter dated January 14, 2014 that “Mr. Yarmoloy has never consented in any way of the original appeal being disposed of, in fact was in discussions about the appeal after the second reassessment was done …” Neither Mr. Richmond nor Mr. Yarmoloy provided information as to when Mr. Yarmoloy was aware of the second reassessment; as a matter of fact he denied knowledge at the hearing of the second assessment.
[13] I have heard no evidence why it was not possible to file a notice of objection to the assessment for 2007, notice of which is dated July 3, 2012.
[Footnote omitted]
[1]2014 TCC 27.