John B Goetz:—This is an appeal with respect to two assessments of the appellant’s liability pursuant to section 160 of the Income Tax Act, SC 1970- 71-72, c 63, as amended. The notices of assessment were dated March 7,

Guy Tremblay [Translation]:—This case was heard at Montreal, Quebec on January 21, 1980.

The Chairman [Translation]:—This is an application to serve a notice of objection beyond the prescribed time limit, under section 167 of the Income Tax Act.

The applicant stated the following:

M J Bonner:—This appellant appeals from assessments of income tax for the 1974, 1975 and 1976 taxation years. The assessments were made on a net worth basis. The parties were agreed that the figures were correct, and it was common ground

M J Bonner:—The appellant appeals from assessments of income tax for the 1977 and 1978 taxation years. On assessment the Minister disallowed an investment tax credit claimed for 1977 and he allowed a lesser credit than was claimed for 1978.

D E Taylor:—These appeals, heard on common evidence in Vancouver, BC, were against income tax assessments for the years 1973, 1974, 1975 and 1976 in which the Minister of National Revenue reclassified certain reported profit arising out of real

Guy Tremblay:—This case was heard in Montreal, Quebec, on May 14, 1981. It was taken under advisement on August 12, 1981, when the last document of the submissions was received by the Board.

M J Bonner:—The appellant appeals from assessments of income tax for the 1977 and 1978 taxation years. He claimed investment tax credits under subsection 127(5) of the Income Tax Act in respect of the capital cost to him

Guy Tremblay [TRANSLATION]:—This case was heard at Quebec City, Quebec on February 21, 1980. It was taken under advisement on May 8, 1980 after final pleadings were filed by the parties.

Guy Tremblay [TRANSLATION]:—These cases were heard on common evidence on March 20, 1979 at Montreal, Quebec.