2024 QCCA 109, 2024 QCCA 109

Wang c. Agence du revenu du Québec 2024 QCCA 109 COURT OF APPEAL CANADA PROVINCE OF QUEBEC REGISTRY OF MONTREAL No.: 500-09-030795-231 ( 500-80-037488-187 ) (500-80-037489-185) MINUTES OF HEARING DATE: January 29, 2024 CORAM: THE HONOURABLE FRANÇOIS DOYON, J.A. CHRISTINE BAUDOUIN, J.A. PETER KALICHMAN, J.A. APPELLANT LONG WANG PRESENT AND UNREPRESENTED RESPONDENT COUNSEL L'AGENCE DU REVENU DU QUÉBEC Mtre STÉPHANIE DOUVILLE ( Revenu Québec ) DESCRIPTION: Respondent’s application to dismiss the appeal (art. 365 CCP ).

Clerk at the hearing : Ariane Simard-Trudel Courtroom: Pierre-Basile-Mignault HEARING 14:11 Commencement of the hearing. Identification of the file and parties. Preliminary remarks by the Court. 14:12 Submissions by Mr. Wang. 14:15 Discussion between the Court and Mr. Wang. 14:21 Recess of the hearing. 14:22 Resumption of the hearing.

14:23 BY THE COURT: Judgment – see page 3. 14:24 Conclusion of the hearing. Ariane Simard-Trudel, Clerk at the hearing JUDGMENT [ 1 ] On November 30, 2023, the appellant appealed from a judgment rendered on November 9, 2022, by the Court of Quebec (the Honourable David L. Cameron), vacating assessments that had been issued by the respondent in two separate files and returning both matters to the Minister for reassessment. [ 2 ] The delay to appeal expired on December 27, 2022, and the appellant did not seek permission to extend it.

Without expressing any view on the merits of the appellant’s arguments, his appeal is outside the delays and must be dismissed. Furthermore, even if the appellant had sought leave to appeal under

article 363 C.C.P ., it would have been dismissed since more than six months have now elapsed since the judgment. FOR THESE REASONS, THE COURT: [ 3 ] GRANTS the motion to dismiss appeal without judicial costs. [ 4 ] DISMISSES the appeal without judicial costs. FRANÇOIS DOYON, J.A. CHRISTINE BAUDOUIN, J.A. PETER KALICHMAN, J.A.