In finding that the word "shall" in s. 166.1(2) was directory rather than mandatory (so that a letter to the Tax Services Office that did not specify reasons for the failure to file a notice of objection within the 90-day period was treated as an application for an extension), Bell T.C.J. stated (at p. 2576):
Section 166.1 obviously is designed to afford relief to a taxpayer who disagrees with an assessment. Although it sets out specific requirements it should not, in these circumstances, be interpreted to foreclose the possibility of an earnest taxpayer, unsophisticated in tax matters, being able to proceed with an appeal. That is simply unjust.