Stone,
J.A:—It
is
clear
to
the
Court
that
the
learned
Tax
Court
of
Canada
Judge
made
no
reviewable
error
in
finding
that
the
applicant’s
income
had
been
properly
assessed
for
the
taxation
years
1982
to
1986
inclusive.
However,
it
is
conceded
by
the
respondent
that
the
penalties
assessed
in
respect
of
this
income
for
each
of
the
years
in
question
were
not
correctly
calculated.
As
correctly
calculated
those
penalties
are:
|
Taxation
Year
|
Penalty
|
|
1982
|
350.62
|
|
1983
|
2,552.92
|
|
1984
|
454.56
|
|
1985
|
1,784.40
|
|
1986
|
311.79
|
The
R.28
application
will
be
allowed
to
this
extent
only
and
the
matter
will
be
referred
back
to
reassessment
accordingly.
Application
allowed
in
part.
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