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

RITCHIE, J.:—This is an appeal by the Minister of National Revenue from a decision of the Income Tax Appeal Board, rendered on December 1, 1954, allowing an appeal from the assessment by the Minister on the income of the respondent company under the