Précis: The taxpayer applied to the Tax Court for an extension of time to file notices of appeal for her 2003 and 2004 taxation years. She argued that she never received the notices of reassessment, did not file notices of objection to them and did not receive notices of confirmation from CRA. Visser J. rejected her application, accepting CRA’s evidence that the notices of reassessment had been sent to her, that her accountant had filed notices of objection and that the reassessments had been confirmed. He drew a negative inference from her failure to call her accountant. The Federal Court of Appeal dismissed the appeal, with costs fixed at $1,000, on the basis that Ms. Gratl had failed to establish a palpable and overriding error on the part of the Tax Court Judge.
Gratl v. R. – FCA: No palpable and overriding error in Tax Court finding that taxpayer received notices of reassessmentREAD MORE »