Heald,
J.:
—While
not
necessarily
subscribing
to
all
of
the
reasons
of
the
learned
Tax
Court
judge,
we
have
not
been
persuaded
that
he
committed
any
error
reviewable
under
section
28.
Once
it
has
been
found
that
there
has
been
no
application
made
for
an
extension
of
time,
the
question
of
whether
or
not
it
would
be
just
and
equitable
to
grant
an
extension
does
not
arise.
Accordingly,
we
think
that
he
properly
dismissed
the
applicant's
application
pursuant
to
section
167
of
the
Income
Tax
Act
(file
A-298-87)
and
that
he
was
also
justified
in
quashing
the
purported
appeals
for
the
taxation
years
ending
February
28,
1979,
June
30,
1979,
June
30,
1980
and
June
30,
1981
(A-297-87).
Both
Section
28
applications
will
therefore
be
dismissed.
Applications
dismissed.
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