Précis: This is a decision in 4 applications to extend the time to file Notices of Appeal. Each of the applicants has been involved in various charitable donation plans (comic books, pens, pencils, etc.). They relied on the promoter of these plans, Mr. Robert Mattacchione (who acted as agent at the hearing), and PAC Protection Corporation (“PAC”), a company affiliated in some way with Mr. Mattacchione, to deal with CRA on objections and appeals. PAC in turn relied upon a lawyer, Mr. Tony De Bartolo, to file appeals to the Tax Court where required. The evidence was that he appears to have failed to file these and other appeals within the time permitted.
Sapi v. R. - TCC: Charitable donation shelter cases - extensions to file a Notice of Appeal deniedREAD MORE »