Question juridique clé
Whether the tax authority proved the date of service of the assessment and whether the objection was timely.
Solution extraite
The assessment was deemed served on 14 November 2016; the objection filed on 20 February 2017 was out of time.
Motifs extraits
The authority bears the burden of proving service, but in mass-mailing cases proof may be established by all circumstances. A delay of more than two months was implausible, especially because a tax refund had already been paid in November 2016, which presupposed a definitive assessment.