M J Bonner:—I will now give my decision in the Hecht and May appeals. I have prepared one set of reasons for all appeals. The appellant Hecht appeals from assessments of tax and penalties for the 1973 and 1974 taxation years. In the

Guy Tremblay [TRANSLATION]:—This case was heard at Sherbrooke, Quebec on January 25, 1979. The matter was taken under advisement on January 9, 1980 following written submissions.

John B Goetz:—These are appeals from reassessments of the appellant’s 1973 and 1974 taxation years.

John B Goetz:—These are appeals by the appellant from his reassessments for the 1975 and 1976 taxation years.

John B Goetz:—This is an appeal by the appellant against a reassessment for the 1977 taxation year. The appellant filed his 1977 income tax return on the basis that he had ceased to be a resident of Canada on July 31, 1977 whereas

John B Goetz:—These are appeals by the appellant against assessments for his 1976 and 1977 taxation years. The appellant is an American citizen and a landed immigrant in Canada. He is a Doctor of Philosophy and when he came to Canada in

John B Goetz:—These are appeals with respect to assessments for the appellant’s 1976 and 1977 taxation years.

John B Goetz:—This is an appeal with respect to the appellant’s 1975 and 1976 taxation years against the respondent’s reassessments for the said years. The appellant was assessed by the Minister as being a person ordi- narily resident in Canada

John B Goetz:—This is an appeal from an income tax reassessment made by the Department of National Revenue with respect to the appellant’s 1972 and 1973 taxation years.

John B Goetz:— This is an appeal from an income tax assessment for the appellant’s 1976 taxation year. The appellant was a retired senior officer of a trust company and with his experience had considerable expertise in making investments.