| Issue: |
Sub-Issue 1: |
Sub-Issue 2: |
Sub-Issue 3: |
| reconsideration of claim |
authority to review |
time limitation |
|
Summary:
This case involves Canada Revenue Agency rulings in 1994 that the claimant's employments in 1990, 1991, 1992 and 1993 to be non-insurable and consequential retroactive decisions of the Commission creating overpayments and imposing penalties for false statements. Over the years, a chain of appeals to the Tax Court, the Federal Court of Appeal and the Board of Referees put into suspension the limitation period, with the result that the limitation period remains intact. Since the penalties imposed on the claimant had been established and were owing before the section on interest came into force, interest must be applied to the claimant's debt.
