Rouleau, J. [Translation]:—This is an appeal pursuant to section 172 of the Income Tax Act, S.C. 1970-71-72, c. 63, as amended, against a decision of the Tax Review Board (now the Tax Court of Canada) which dismissed the taxpayer's

Pinard, (.[Translation]:—This is an appeal in the form of an action pursuant to subsections 172(2) and 175(3) of the Income Tax Act, SC 1970-71-72, c 63, as amended, brought by the taxpayer Louis Vaillancourt against a notice of