“[3] With respect to the reassessments for the reporting periods ending December 31 of 2006, 2007, 2008 and 2010, the Respondent filed affidavit evidence to show that Mr. Mackey had not filed notices of objection to those reassessments. Section 306of the Excise Tax Act (Act) requires that a taxpayer file a notice of objection prior to commencing an appeal in this Court. Therefore I agree with the Respondent that the Court lacks jurisdiction to decide the appeal for those periods and the appeal for those periods must be quashed.
“[5] I am satisfied that all of the issues raised by Mr. Mackey for the remaining period in issue relate to the manner in which the CRA accounted for payments of GST made either by him or on his behalf by the real estate brokerage he worked for. Mr. Mackey is not disputing the amount of net GST reassessed for the period. In fact, he was reassessed in accordance with the revised GST return he filed for the period on December 15, 2011. The dispute he has relates to the determination of the balance owing on his GST account and how the CRA accounted for payments made by him.
“[7] It is clear then, that this Court only has jurisdiction to determine the correctness of the amount of tax assessed and not matters relating to the payment of tax after it has been assessed. Since Mr. Mackey is not challenging the amount of net tax assessed for the period the Court has no jurisdiction to grant him any relief. Therefore, the Respondent’s motion to quash the appeal for the period ending December 31, 2009 is also granted.”