The taxpayer was the result of a 1974 amalgamation of two Alberta corporations, one of which was a second successor corporation for purposes of s. 29(29) of the ITARs respecting exploration and drilling expenses made prior to 1972. Hugessen J.A. held that because the taxpayer was a new corporation for income-computation purposes and was not the second successor corporation, there was no provision of the Act permitting it to deduct oil and gas exploration expenses incurred by other taxpayers. With respect to the effect of the reasons of MacGuigan J.A. in the Guaranty Properties case, he indicated (at p. 6416) that they only established that "the provisions of paragraph 87(2)(a) are applicable only to the amalgamated company's computation of income under Division B (including the 'deductions to which it may be entitled') and, where necessary as a consequence thereof, to its computations of taxable income (Division C) and of tax (Division E)", and that the decision "should not be read as denying that the amalgamated corporation is to be deemed to be a new corporation for all purposes relating to the computation of its income".