PART 1
STATEMENT OF FACTS
REPLY
In reply to the Notice of Appeal with respect to the Part I.3 Reassessment for the Appellant's 1994 taxation year, the Deputy Attorney General of Canada, on behalf of the Respondent, says as follows:
A. STATEMENT OF FACTS
- Except as expressly admitted hereinafter, he denies the allegations of fact contained in the Notice of Appeal.
- He admits the allegations of fact contained in paragraphs 1, 2, 11, 13 and 14 of the Notice of Appeal.
- With respect to paragraph 3 of the Notice of Appeal, he admits that the Appellant carried on business as a forestry and lumber company and that its operations included harvesting of timber on private timberlands and Crown timber tenures. He says further that the Appellant's operations also included two lumber mill complexes which manufactured lumber and other wood products.
- With respect to paragraphs 4 and 5 of the Notice of Appeal, he denies that the Appellant's financial statements for its 1994 taxation year contained the . . .
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PART 1
STATEMENT OF FACTS
REPLY
TFL Forest Ltd. is a logging company. In 1994 it computed its corporate tax liability on the basis that it was entitled to deduct its estimates of future expenses for silvaculture and environmental costs.
The issue is whether TFL's future expenses for silvaculture and related environmental are deductible under the Canadian Tax Code.
The Income Tax Act provides that future expenses are deductible when they fall within the categories specified in Section 20.
Because expenses for future silvaculture and related environmental costs do
not fall within the categories specified in Section 20, they are not deductible.
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