The taxpayer had business deductions disallowed in late 2014 for the 2011 and 2012 tax years. The taxpayer had provided a lot of documentation over the course of the review, but the two returns were ultimately reassessed in May 2015. In January 2018, the taxpayer contacted the CRA with more information and the CRA said it’s too late. The taxpayer applied to the Tax Court to force CRA to accept the Notice of Appeal and the new information. The Tax Court also said it was too late. The Tax Court did point out that the CRA had the discretion to accept it and that the Tax Court would support the CRA in their decision.