http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/72428/index.do 
Hamer v. The Queen (July 8, 2014 – 2014 TCC 218) was an application to extend the time to file a notice of objection. At the original hearing the taxpayer claimed that he had problems with his mail service and had not received the notice of reassessment. The hearing was adjourned to permit the Crown to adduce evidence that the reassessment was in fact mailed. The Crown then introduced an affidavit to establish the mailing of the reassessment but the Court did not find the affidavit evidence acceptable:
[12] I make the following observations about the affidavit.
[13] First, the key facts in the affidavit are not within the knowledge of Mr. Momoh. He relies instead on information provided to him by Debra Desmarais and Christopher Hummel. What is the point of having a sworn affidavit if the people with the information are not required to swear the accuracy of their statements?
[14] Second, the affidavit provides only a bare-bones description of the mailing of this particular notice of reassessment. The affidavit is lacking in detail in important respects. For example, Mr. Momoh states the conclusion of Ms. Desmarais that the notice of reassessment was released in DAS 75 but there is no detail as to how this conclusion was reached. There is a similar problem with the conclusion of Mr. Hummel that the counts were accurate. In addition, the conclusion reached by Mr. Momoh in paragraph 10 provides no detail at all except that it is “upon review of the Agency’s records.” These brief conclusions do not provide me with confidence that the statements are accurate.
[15] This lack of detail may be contrasted with the thorough evidence provided in Abraham v The Queen, 2004 TCC 380. I am not suggesting that the level of detail provided in Abraham is necessary in each case. However, the evidence must be better than is provided in Mr. Momoh’s affidavit.
[16] Third, Mr. Momoh’s affidavit may be based on a standard form. I note in particular that it is very similar to an affidavit filed in this Court in Nicholls v The Queen, 2011 TCC 39.
[17] Simply put, I do not have adequate reasons to have confidence as to the diligence that Mr. Momoh, Ms. Desmarais or Mr. Hummel took to this matter.
[18] Fourth, I note that none of the CRA officials were available for cross‑examination. I would not find this to be fatal if I were otherwise satisfied as to the reliability of the affidavit, but I do have concerns in this case.
[19] For these reasons, I conclude that the Crown has not provided sufficient reliable evidence that the 2008 notice of reassessment was mailed to Mr. Hamer. Without this evidence, it is not sufficient for the Crown to point to problems that Mr. Hamer was having with Canada Post.
As a result the application was granted.