- 25 - 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 affectPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011