Reasons for Decision
1
Is there an acceptable explanation for the delay and is it fair and reasonable in all the circumstances to extend the time. In considering whether there is an acceptable explanation of the delay, it will be relevant to consider what action a taxpayer has taken to make the Commissioner aware that he or she contests the finality of the decision.
2
Is there any prejudice to the Commissioner if an extension is granted? The mere absence of prejudice to the Commissioner will not, of itself, be sufficient to justify an extension.
3
The merits of the substantive application, that is, of the objection itself.
4
Considerations of fairness as between the applicant and other persons in a similar position.