While the taxpayer's file for 2007 was on hold, pending the determination of a question in common with other taxpayers, the taxpayer submitted a T1 Adjustment Request to allow carrying charges. The Minister allowed the Request and issued a further reassessment. The taxpayer neglected to file a new notice of objection, and he took more than a year and 90 days to file his application to extend the time to file a notice of objection.
Woods J dismissed the taxpayer's application to allow the extension application. There is no basis on which to extend the s. 166.2(5)(a) deadline (para. 18).
(The decision ultimately favoured the taxpayer, as Woods J also found that the latest reassessment was barred - see summary under s. 152(4.2).)