Précis: The taxpayer failed to file returns for 1999 to 2002. In 2004 she was assessed for each of those years and did not file a notice of objection. In 2013 she filed returns for 1999-2012. The 2003-2012 returns were assessed as filed but the 1999-2002 returns were returned to her and not further assessed. She filed a notice of objection in 2013 to the years 1999 to 2012. On March 3, 2015 CRA confirmed its position. On May 9, 2016 the taxpayer filed an application to extend the time to file a Notice of Appeal but it was not perfected (by inclusion of a draft Notice of Appeal) until June 7, 2016.
Carpenter v. R. - TCC: Taxpayer out of time for extension of time to file Notice of AppealREAD MORE »