John B Goetz:—This is an appeal by the appellant with respect to its 1977 taxation year. At the outset of the hearing, by agreement between counsel, it was agreed that the issues involved would apply as well to the 1978 taxation year.

Guy Tremblay:—These cases were heard in Sudbury, Ontario on June 17, 1981. At the beginning of the trial it was agreed between the parties that the cases be heard on common evidence because the various reassessments involved in the cases relate to

Guy Tremblay:—This application was heard in Montreal, Quebec, on September 25, 1981. It was taken under advisement on November 24, 1981, when the last written argument was received by the Board.

The Chairman:—This is an application under section 167 of the Income Tax Act by which Mr Keith Lehrer seeks to obtain an Order from the Board extending the time in which he may, after expiration of the prescribed delay, file

Assistant Chairman:—Florence Epstein has appealed to this Board from an assessment of income tax for the 1975 taxation year. For that year, the respondent added to her income the sum of $11,200. The issue is whether or not that sum was correctly

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