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Parsons OMT Report. Parsons analyzed returns as filed; i.e.,
before assessment by the Mine Assessor. Later, Parsons obtained
records of the Mine Assessor’s adjustments to the filed returns.
He included assessment data in his rebuttal memorandum to the
extent it was available. The parties stipulated that the data
(but not the opinions and conclusions) in the Parsons OMT Report
was accurate.
Of the 213 returns that Parsons reviewed, 145 returns (68.1
percent) reported OMT liability. Nonrecoverable expenses exceed
the processing allowance on only 19 of the OMT returns which
reported OMT liability (15.8 percent).
The Parsons OMT Report shows that, in the aggregate,
processing allowances claimed by OMT taxpayers dwarfed
nonrecoverable expenses:
Millions of Can$
Nonrecoverable Processing
Year Expenses Allowance
1968 10.6 91.6
1969 9.7 76.3
1970 30.2 99.7
1971 39.6 36.9
1972 51.7 92.6
1973 54.1 140.6
1974 57.6 196.8
1975 61.6 252.2
1976 70.0 217.8
1977 73.3 43.2
1978 83.4 94.7
1979 64.1 321.8
1980 99.3 573.5
Total 705.2 2,237.7
Average 54.3 172.1
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