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For the 13-year period, the total amount of processing
allowance claimed on returns in the Parsons OMT Report was
Can$2,237,700,000, which is more than three times the total
amount of nonrecoverable expenses (Can$705,200,000).
Parsons concluded that the aggregate amount of processing
allowance claimed by OMT taxpayers in his report exceeded their
aggregate amount of nonrecoverable expenses by 3.2 to 1.
Respondent does not dispute that conclusion. Total processing
allowances claimed on returns exceeded nonrecoverable expenses
for 11 of the 13 years in the Parsons OMT Report.
The Parsons OMT Report also shows that the processing
allowances claimed by the vast majority of OMT taxpayers in the
study exceeded those taxpayers' nonrecoverable expenses. The
Parsons OMT Report also shows that nonrecoverable expenses
exceeded processing allowances in 21 of 145 returns from eight
OMT taxpayers.
4. Respondent’s Expert
Hallett concluded that nonrecoverable expenses exceeded the
processing allowance in only 60 of 213 OMT returns in the Parsons
OMT Report if all OMT returns are considered, whether or not tax
was due. Nineteen of those 60 returns were from taxpayers that
owed OMT.
Hallett stated his opinion that the nonrecoverable expenses
were significant. His opinion, even if correct, does not affect
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