http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/67127/index.do 
Furlong v. The Queen[1] (March 5, 2014) involved the taxpayer’s attempt to appeal the Minister’s refusal of a T1Adjustment Request seeking to claim an interest deduction for prior taxation years (2007, 2008 and 2009).
The taxpayer, who was represented by his son in the proceeding, raised an interesting argument asserting that the Tax Court had jurisdiction. Unfortunately for the taxpayer, the court did not find the argument persuasive:
[20] In particular, Mr. Furlong submits that the denial of the T1 Adjustment Request is a determination referred to in subsection 152(4.3) of the Act. He further submits that subsection 165(1.1) of the Act gives this Court jurisdiction to hear appeals with respect to such determinations. These provisions are reproduced below.
152.(4.3)
Consequential assessment – Notwithstanding subsections (4), (4.1) and (5), i
f the result of an assessment or a decision on an appeal is to change a particular balance of a taxpayer for a particular taxation year, the Minister may,or if the taxpayer so requests in writing, shall, before the later of the expiration of the normal reassessment period in respect of a subsequent taxation year and the end of the day that is one year after the day on which all rights of objection and appeal expire or are determined in respect of the particular year, reassess the tax, interest or penalties payable by the taxpayer, redetermine an amount deemed to have been paid or to have been an overpayment by the taxpayer or modify the amount of a refund or other amount payable to the taxpayer, under this Part in respect of the subsequent taxation year, but only to the extent that the reassessment, redetermination or modification can reasonably be considered to relate to the change in the particular balance of the taxpayer for the particular year. (Emphasis added)
165.(1.1)
Limitation of right to object to assessments or determinations -Notwithstanding subsection 165(1),
where at any time the Minister assesses tax, interest, penalties or other amounts payable under this Part by, or makes a determination in respect of, a taxpayer
(a) under subsection 67.5(2) or 152(1.8), subparagraph 152(4)(b)(i) or
subsection 152(4.3) or (6), 161.1(7), 164(4.1), 220(3.4) or 245(8) or in accordance with an order of a court vacating, varying or restoring an assessment or referring the assessment back to the Minister for reconsideration and reassessment,
(b) under subsection 165(3) where the underlying objection relates to an assessment or a determination made under any of the provisions or circumstances referred to in paragraph 165(1.1)(a), or
(c) under a provision of an Act of Parliament requiring an assessment to be made that, but for that provision, would not be made because of subsections 152(4) to 152(5),
the taxpayer may object to the assessment or determination within 90 days after the day of sending of the notice of assessment or determination, but only to the extent that the reasons for the objection can reasonably be regarded
(d) where the assessment or determination was made under subsection 152(1.8), as relating to any matter or conclusion specified in paragraph 152(1.8)(a), 152(1.8)(b) or 152(1.8)(c), and
(e) in any other case, as relating to any matter that gave rise to the assessment or determination and that was not conclusively determined by the court, and this subsection shall not be read or construed as limiting the right of the taxpayer to object to an assessment or a determination issued or made before that time.
(Emphasis added)
[21] The problem that I have with this argument is that a determination regarding a T1 Adjustment Request is not a determination contemplated by subsection 152(4.3) of the Act.
[22] This provision is designed to require the Minister to issue consequential reassessments to conform with changes that are made in an “assessment” or in a “decision on an appeal.”
[23] In the circumstances of this case, Mr. Furlong does not seek conformity with an “assessment” or a “decision on an appeal.” Accordingly, subsection 152(4.3) has no application.
[24] Gary Furlong also referred me to comments by judges of this Court to the effect that it is preferable for appeals be heard on their merits rather than being decided on procedural grounds.
[25] I agree with this sentiment, but provided that the relief sought is not prohibited by the Act. Unfortunately for Mr. Furlong, the relief that he seeks is clearly prohibited.
[1] *.