KEARNEY, J.:—This is an appeal from a decision of the Tax Appeal Board, dated January 8, 1962 (28 Tax A.B.C. 221), dismissing the appellant’s appeal from a re-assessment of its declared income for its taxation year 1959, notice of which was given by the Minister on August 23, 1960, and whereby losses incurred in the construction and sale of homes, amounting to $134,667, during the years 1956 to 1959, inclusive, and claimed in full as deductions by the taxpayer, were disallowed to the extent of 25% thereof or $33,667.