Gidda v. The Queen, 2013 DTC 1158 [at at 871], 2013 TCC 190 -- summary under Subsection 167(5)

The taxpayers were two individuals and two corporations, with one individual taxpayer acting on behalf of all four. The representative taxpayer had filed the appeals with the CRA rather than the Tax Court Registry. C Miller J found that the taxpayers could not avail themselves of the Hickerty principle to suspend the one-year grace period, because in this case it was unreasonable for the taxpayers to believe that they had validly instituted an appeal. The representative taxpayer had persistently ignored communication attempts from CRA, and had been involved in prior tax appeals as an appellant and as an agent.