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February 24, 2020

Did not get her mail

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A taxpayer filed for extensions to file notices of appeal.  Her excuse was that she had not received her notices of assessment.  Her application was denied as the Tax Court found that in all probability, the CRA did mail them, and she did get them.  She appealed this decision too.  The Federal Court of Appeal determined she could not establish that the Tax Court made a palpable and overriding error in it’s core finding of fact.  She lost again.

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