I’m used to hearing about taxpayers who file objections or appeals to the Tax Court late, but poor Mr Jablonski filed his objection too early (Jablonski v R, 2012 TCC 29). He objected to a reassessment before the end of the 90-day limitation period. Unfortunately, he also filed the objection before the reassessment was even issued, which invalidated the objection. What’s worse, he didn’t re-file the objection after the reassessment was actually issued, and he didn’t apply to the CRA for an extension of time within which to file the objection. The Tax Court, then, also dismissed his application for the extension.
