Gibson, J.:—This is an appeal from an assessment dated January 2, 1968 under the Estate Tax Act wherein an estate tax in the sum of $59,592.04 was assessed in respect to the estate of Kate Daintry Malloch, deceased.

KERR, J.:—This is an appeal from the income tax assessment of the appellant company, hereinafter sometimes called ‘‘Bel- Conn”, for its taxation year 1962. The sole issue in the appeal is whether the profit made by the company from the sale of its