On August 26, 2019, the Minister reassessed the taxpayers for the full amount of a new residential rental unit rebate (“rebate”), previously paid in 2015, plus accrued interest, on the basis that the taxpayers had failed to provide supplemental information within the required time period after a 2018-19 follow-up audit. The taxpayers provided much of that supplemental information on September 4, 2019 along with a covering letter, which stated that it was “to request a re-assessment of case #50499531.” The taxpayers received confirmation of receipt of the letter and spoke with CRA representatives, but did not file an application to extend the time to file a notice of objection until January 22, 2021. In finding that the taxpayers’ submission qualified as an objection sufficient for the purposes of s. 301(1.1), Bocock J stated (at paras. 22, 27):
The form [of the submission] was not usual, but there is no prescribed form.
… The submission, dated two weeks after the notice of reassessment, while not perfectly detailed, was sufficient to initiate the objection process responsive to an audit and conclusions already in active dispute. … The Minister has not considered the objection as she should have done. …