Précis: The taxpayer was involved in a complex and lengthy series of GST audits by Agence du Revenu du Québec (the ARQ) (the factual background occupies some 50 paragraphs of the Tax Court’s 80 paragraph decision). They failed to file Notices of Objection within the statutory limits and applied to ARQ for an extension, which was denied. They then applied to the Tax Court for an extension, which was allowed. This was clearly a case of simple stubbornness on the part of ARQ since, as Justice D’Auray illustrates, there is ample precedent for granting extensions in similar circumstances.
Les immeubles Caris v. R. - TCC: Court grants extension of time to file GST notices of objectionREAD MORE »