Taylor,
TCJ:—This
is
an
application
for
an
extension
of
time
within
which
to
file
notices
of
objection
to
assessments
for
the
years
1975,
1976,
1977
and
1978.
It
was
heard
in
St
John’s,
Newfoundland,
on
July
4,
1983
in
my
capacity
as
a
member
of
the
Tax
Review
Board
but
these
reasons
are
given
in
my
present
capacity
as
a
judge
of
the
Tax
Court
of
Canada.
Certain
explanations
regarding
dates,
meetings,
correspondence,
etc
were
provided
to
the
Board
by
counsel
for
the
applicant
and
the
Board,
in
order
to
consider
these
explanations
adequately,
reserved
this
decision.
However,
it
appears
definite
that
the
application
was
not
made
until
March
10,
1983,
whereas
the
assessments
at
issue
were
dated
May
16,
1980.
The
contention
of
the
Minister
that
the
Board
(as
it
was
at
that
time)
has
no
jurisdiction
to
grant
the
requested
extension
of
time
must
be
upheld,
and
the
application
is
dismissed.
Application
dismissed.
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