CanLII - Fédéral - R.S.C. 1985, c. T-2

18.16 (1) The Minister of National Revenue shall file a reply to a notice of appeal within sixty days after the day on which the Registry of the Court transmits to that Minister the notice of appeal unless the appellant consents, before or after the expiration of the sixty day period, to the filing of that reply after the sixty day period or the Court allows the Minister, on application made before or after the expiration of the sixty day period, to file the reply after that period.

Time limit for reply to notice of appeal	18.16 (1) The Minister of National Revenue shall file a reply to a notice of appeal within sixty days after the day on which the Registry of the Court transmits to that Minister the notice of appeal unless the appellant consents, before or after the expiration of the sixty day period, to the filing of that reply after the sixty day period or the Court allows the Minister, on application made before or after the expiration of the sixty day period, to file the reply after that period.
Exception	(2) Notwithstanding subsection (1), where an application is made pursuant to subsection 18.11(1) to have an appeal heard in accordance with the general procedure, the Minister of National Revenue need not file a reply to the notice of appeal until the Court decides which procedure applies in respect of the appeal.
Time after refusal	(3) Where the Court dismisses an application referred to in subsection (2), the Minister of National Revenue shall file a reply to a notice of appeal on or before the later of (a) a day that is sixty days after the day on which the Registry of the Court transmits to that Minister the notice of appeal, and (b) a day that is thirty days after the day the written judgment dismissing the application is received by the Minister from the Registry of the Court, unless the appellant consents, before or after the time referred to in paragraph (a) or (b), to the filing of the reply at a later date or the Court allows the Minister, on application made before or after the time referred to in paragraph (a) or (b), to file the reply after that time.
Where reply not filed in time	(4) The Minister of National Revenue may file a reply to a notice of appeal after the period limited under subsection (1) or (3), as the case may be, and where that Minister files the reply after that period or after the extension of time consented to by the appellant or granted by the Court, the allegations of fact contained in the notice of appeal are presumed to be true for the purposes of the appeal.
Interpretation	(5) The Minister of National Revenue may file a reply to a notice of appeal by mail and any such reply filed by mail shall be deemed to have been filed on the day on which it is mailed. R.S., 1985, c. 51 (4th Supp.), s. 5; 1993, c. 27, s. 218.