The taxpayer missed the deadline for filing a Notice of Appeal. His accountant represented him at Court and got an extension of time allowing him to file a proper Notice of Appeal in 30 days. They did nothing for 600 days. Then, discovering that CRA was collecting the taxes due for the appealed years, they applied to the TCC for another extension of time. The TCC refused. The taxpayer did not give “a satisfactory explanation that would justify setting aside the [earlier extension] Order in question and reopening his file.”
Salari Kamangar v. The Queen, (2013 TCC V. Miller) — If the TCC gives you an extension of time to file an appeal but you don’t bother, you can lose your appeal right
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