GIBSON, J.:—This is an appeal from the judgment of the Tax Appeal Board, dated February 9, 1965 (37 Tax A.B.C. 365) by the Minister of National Revenue in respect of the income tax assessment of the respondent for the 1957, 1958, 1959 and 1960

GIBSON, J.:—This appeal is concerned with the 1962 income tax year of the appellant. The appellant seeks to deduct in computing its income for 1962 the sum of $209,600 being the sum allocated by the appellant of the purchase price paid by the