After the normal reassessment period for assessing its 2002 to 2005 taxation years had passed, the taxpayer requested the Minister to reassess those years to allow capital cost allowance for its pipelines on the basis they were Class 6 rather than Class 1 assets. In denying the taxpayer's application for an extension of the time to file notices of objection for those years, D'Auray J stated (at para. 21):
[T]he Minister does not have to accept or act upon an amended return and reassess a taxpayer.