W O Davis:—This appeal was heard before me at Calgary, Alberta on November 8, 1971 at a sittings of the Tax Appeal Board as it was then constituted.

Maurice Boisvert:—This case concerns a motion to obtain an extension of time to appeal from assessments dated November 12, 1970 covering the taxation years 1961 to 1967 inclusive.

Roland St-Onge:—For the reasons put forward in Leo O Lund v MNR, in which judgment was delivered today, these appeals are also dismissed.

Appeals dismissed.

SWALLOWFIELD FARMS LTD, Appellant,

and •*

MINISTER OF NATIONAL REVENUE, Respondent.

Tax Review Board (J O Weldon, QC), February 17, 1972.

Income Tax Act, RSC 1952, c 148 — 3, 4, 139(1)(e) — Real estate transaction

Roland St-Onge:—This appeal was heard at Vancouver, BC on October 26, 1971 by the Tax Appeal Board as it was then constituted.

In his statement of facts the appellant alleged the following:

Roland St-Onge:—This appeal was heard at Montreal, Province of Quebec, on March 18, 1971 by the Tax Appeal Board as it was then constituted. The question to be decided herein is whether a company known as Jodol Holdings Ltd carried on an active commercial

W O Davis:—Andrew Graham Tulloch has appealed from an assessment to income tax dated July 18, 1969 in respect of his 1964 taxation year, wherein the net proceeds from the sale of a vessel known as the “Sea Prince” have been added to his reported

Roland St-Onge:—This appeal was heard at Vancouver, BC on October 29, 1971 by the Tax Appeal Board as it was then constituted, and is from reassessments dated October 20, 1969 wherein tax in the amounts of $6,205.70, $4,019.39 and $10,194.14 was levied in

W O Davis:—In this matter, the appellant company has appealed from a notice of reassessment dated October 21, 1970, whereby the Minister of National Revenue informed the appellant that the tax payable by it in respect of its 1969 taxation year was nil.

A J Frost:—This is an appeal from four assessments, each one dated March 17, 1969, in respect of the appellant’s taxable income for the years 1963,1964, 1965 and 1966.

A J Frost:—This is an appeal from three income tax assessments each dated October 30, 1969 in respect of the appellant’s taxation years 1966, 1967 and 1968, wherein tax in the amounts of $80, $253 and $2,512.88 was levied. Upon Notices of Objection duly