Grant, DJ:—This is an appeal by the plaintiff from a decision of the Tax Review Board dated December 13,1977, whereby it allowed the defendant’s appeal from the reassessment of his income tax returns for the year 1975 by the Minister of National

J Jerome, ACJ:—In this case the facts are agreed and there is no dispute.

Maguire, DJ:—This matter came before me at Regina, Saskatchewan, on October 15, 1980. An event beyond my control has resulted in rather a lengthy delay in delivery of my judgment.

Marceau, J [TRANSLATION]:—A certificate in accordance with subsection 223(2) of the Income Tax Act filed in the registry of the Court on August 14, 1978, establishing that defendant owed Her Majesty a sum of over $17,000. The