Précis: The taxpayer was assessed for GST in 2009. In 2015 she wrote the Minister asking for an extension of time to file a notice of objection. The request was refused because it was outside the time limits for applying for an extension under the Excise Tax Act. Ms. Feng applied to the Federal Court to review that decision of the Minister. The Crown moved to strike the application on the basis that it was bereft of any possibility of success. The Prothonotary struck the application as an abuse of process and an impermissible collateral attack on the Minister’s decision. The Crown was awarded costs of $750 inclusive of disbursements and taxes.
Feng v. R. - FC: No judicial review of objection extension application filed 4 ½ years lateREAD MORE »