BETWEEN:
and
Heard at Toronto, Ontario, on October 17, 2006.
Judgment delivered from the Bench at Toronto, Ontario, on October 17, 2006.
REASONS FOR JUDGMENT OF THE COURT BY: MALONE J.A.
Docket: A-4-06
Citation: 2006 FCA 333
CORAM: LINDEN J.A.
NADON J.A.
MALONE J.A.
BETWEEN:
HERMAN GEBELE
Appellant
and
HER MAJESTY THE QUEEN
Respondent
REASONS FOR JUDGMENT OF THE COURT
(Delivered from the Bench at Toronto, Ontario, on October 17, 2006)
[1] We are all satisfied that the Tax Court Judge did not commit any legal or factual errors that would warrant our intervention.
[2] Based on the evidence, there was no basis upon which the time for extending the service of the Notice of Objections for the 1988 to 1994 tax years pursuant to paragraph 166.2(1)(a) of the Income Tax Act could be extended.
[3] The respondent sought and should receive its costs.
FEDERAL COURT OF APPEAL
NAMES OF COUNSEL AND SOLICITORS OF RECORD
DOCKET: A-4-06
(APPEAL FROM AN ORDER OF THE HONOURABLE JUDGE SHERIDAN, TAX COURT OF CANADA DATED DECEMBER 9, 2005, DOCKET NO. 2004-3293(IT))
STYLE OF CAUSE: HERMAN GEBELE
v.
HER MAJESTY THE QUEEN
PLACE OF HEARING: TORONTO, ONTARIO
DATE OF HEARING: October 17, 2006
REASONS FOR JUDGMENT OF THE COURT BY: Linden, Nadon & Malone JJ.A.
DELIVERED FROM THE BENCH BY: Malone J.A.
APPEARANCES:
|
FOR THE APPELLANT
|
|
|
Kandria Airde |
FOR THE RESPONDENT
|
SOLICITORS OF RECORD:
|
Hamilton, Ontario |
FOR THE APPELLANT
|
|
Deputy Attorney General of Canada Toronto, Ontario |
FOR THE RESPONDENT
|