- Parties: The appellant was Denise C. Nagel. The respondent was His Majesty the King.

- Subject Matter: This case arose from nil assessments and notices of determination issued by the Canada Revenue Agency regarding the appellant’s 2016, 2017, and 2018 tax years and a re-determination concerning her 2018 tax year. The Tax Court of Canada quashed her appeals and dismissed her motion to strike the respondent’s amended replies in her appeals. This appeal challenged the Tax Court’s decision.

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal. Regarding the appellant’s argument that the second nil assessment concerning her 2013 tax year was invalid and should not have been included in the amended replies, the appeal court saw no reason to intervene, given that the Tax Court made no finding on the second nil assessment’s validity. Regarding the appellant’s claim that the original replies in her underlying Tax Court appeals were late, the appeal court disagreed that the original replies were filed late, given the six-month suspension of deadlines in s. 6(1) of the Time Limits and Other Periods Act (COVID-19), 2020. The appeal court was unconvinced that the Tax Court erred in its exercise of discretion to accept the amended replies.

- Date: The hearing was set on Nov. 13, 2024. The court released its decision on Nov. 13, 2024.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: The appeal court awarded costs in the all-inclusive amount of $200.