Roland St Onge [Translation] —The appeal of Mr Sylvio Paquet came before me on January 21, 1981 in the city of Montreal, Quebec. At issue is whether the profits generated from the sale of certain lots must be considered business income

John B Goetz:—This is an appeal by the appellant with respect to his assessments for the 1975, 1976 and 1977 taxation years.

Guy Tremblay:—This case was heard in Sudbury, Ontario, on June 18, 1981.

Guy Tremblay [Translation]:—This case was heard at Montreal, Quebec on September 19, 1979.

Guy Tremblay:—These cases were heard in Calgary, Alberta on January 15, 1981. They were taken under advisement on reception of the stenographic notes on February 26, 1981. Since the various assessments of tax issued against the above appellants relate to

Guy Tremblay:—This case was heard in Montreal, Quebec on November 3, 1980. The case was taken under advisement on January 15, 1981 when the documents concerning this case were received by the Board.

M J Bonner:—This is an appeal from an assessment of income tax for the 1978 taxation year. In his return of income the appellant claimed, under subsection 110.2(2) of the Income Tax Act, a deduction in the computation

Guy Tremblay:—These cases were heard on common evidence in Edmonton, Alberta on June 4, 1981.

D E Taylor [Translation]:—This appeal was heard in the city of Montreal, Quebec on November 17, 1980. It was filed in respect of tax assessments for 1976 and 1977, in which the Minister of National Revenue refused to allow the appellant

The Chairman:—The appeal of John David Philp is from an assessment with respect to the 1976 taxation year. In his Notice of Appeal the appellant claims: