Taxpayer challenge to timeliness of Commissioner's Statement of Position (CSOP) dismissed by TRA

The Commissioner’s Statement of Position (CSOP) was issued within the relevant response period even if it was not received within that response period.

In regard to email, these are received when the email leaves the information system of the sender and enters the information system of the recipient.

“Information system” is not confined to a specific part of an information system (such as an email address) but extends to the architecture needed to produce, send, receive, store, display, or otherwise process electronic communications.