THORSON, P.:—This is an appeal from the decision of the Income Tax Appeal Board, sub nom. No. 260 v. M.N.R. (1955), 13 Tax A.B.C. 27, dated April 29, 1955, allowing the respondent’s appeal against its Income tax assessment for 1951.

The issue is similar to that in M.N.R. v. Eastern Textiles Ltd., in which I have just delivered judgment, namely, whether: the respondent in computing its income for 1951 was entitled to deduct the business losses sustained by it in 1946 and 1947.

THORSON, P.:—This is an appeal from the decision of the Income Tax Appeal Board, sub nom. No. 280 v. M.N.R. (1955), 13 Tax A.B.C. 362, dated August 30, 1955, allowing the respondent’s appeal from its income tax assessment for 1951.

The respondent’s fiscal year ended on October 31 and so did its taxation year, so that when I refer in these reasons for judgment to a year I mean the year ending on October 31 in such year.

THORSON, P.:—This is an appeal from the decision of the Income Tax Appeal Board, sub nom. No. 262 v. M.N.R. (1955), 13 Tax A.B.C. 33, dated May 4, 1954, dismissing the appellant’s appeal against its income tax assessment for 1952.

THORSON, P.:—These two appeals were heard together. The first is an appeal by the taxpayer against its income tax assessment for 1945 and its excess profits tax assessment for 1945, 1946 and 1947. The second is an appeal by the Minister from the