Précis: The Azzopardi brothers, Thomas and Emmanuel, were limited partners of the same partnership. They applied to extend the time to file individual notices of appeal or notices of objection for a variety of taxation years. The Crown consented to most of the applications but did not consent to Emmanuel’s application in respect of 2002 because it was a nil assessment. In the case of Thomas’ application for 2011 and 2012 the Crown pointed out that the Court was without jurisdiction because Thomas had failed to apply within the period during which the Court had jurisdiction to grant relief. There were no orders as to costs.
Azzopardi v. R. - TCC: Extension applications a comedy of errorsREAD MORE »