KEARNEY, J.:—This is an appeal from a decision of the Tax Appeal Board dated November 28, 1961 (28 Tax A.B.C. 204), wherein an appeal by the respondent from a re-assessment made by the Minister, which added $169,533.50 to the taxpayer’s previously declared

Ritchie, D.J.:—This appeal is from a decision of the Tax Appeal Board allowing in part an appeal from a May 14, 1958 re-assessment of income tax by the Minister of National Revenue adding $60,240.51 to the income reported by the appellant for the