- Parties: The appellant was Sodecia Canada Investments Inc. The respondent was His Majesty the King. 

- Subject Matter: The appellant in this tax case appealed a 2017 notice of assessment. The Minister of National Revenue moved to quash the appeal on the basis that the appellant failed to file a notice of objection within the 90-day limit required by the Income Tax Act, 1985. The Tax Court of Canada granted this motion, which prompted the appellant to appeal. 

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal. The appeal court saw no palpable and overriding errors in the tax judge’s assessment of the evidence. First, the appeal court deemed it sufficient that the officer knew about the practices and procedures of the Canada Revenue Agency with respect to the preparation, transmission between offices, and ultimate mailing of the notices of assessment. The appeal court found no requirement for personal knowledge as to what happened in the past. Second, the appeal court noted that the appellant was essentially asking it to reweigh the evidence and to disagree with the Tax Court judge’s factual findings. The appeal court concluded that it would not interfere in such matters without the appellant establishing a palpable and overriding error. 

- Date: The hearing was set on Dec. 16, 2024. The court released its decision on Dec. 20, 2024. 

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

- Amount: The appeal court fixed costs at $1,500.