1.
subsection
80(1)
of
the
Income
Tax
Act
(the
“Act”)
does
not
apply
to
reduce
the
appellant’s
non-capital
losses
with
the
result
that:
(a)
the
appellant’s
1981
non-capital
loss
was
$23,819,719
of
which
$5,752,422
is
deductible
in
computing
taxable
income
for
1983;
$2,732,328
is
deductible
in
computing
taxable
income
for
1985;
and
$15,334,969
is
deductible
in
computing
taxable
income
for
1986;
(b)
the
appellant’s
non-capital
loss
for
the
1982
taxation
year
was
$28,236,107
of
which
$13,501,728
is
deductible
in
computing
taxable
income
for
1986
and
$14,734,379
is
deductible
in
computing
taxable
income
for
1987;
and
(c)
the
appellant’s
non-capital
loss
for
1984
was
$23,057,318
of
which
$22,379,442
is
deductible
in
computing
taxable
income
for
1987
and
$677,876
remains
deductible
in
years
after
1987.
2.
The
issue
related
to
silviculture
costs
is
not
conclusively
determined
by
this
judgment
and
the
determination
thereof
shall
abide
the
principle
or
principles
defined
upon
the
final
disposition
of
all
appeals
in
actions
94-1737(IT)I
and
95-1335(IT)G
in
which
the
taxpayer
was
Northwood
Pulp
and
Timber
Ltd.
[Northwood
Pulp
&
Timber
Ltd.
v.
R.,
[1996]
2
C.T.C.
2123,
96
D.T.C.
1104
(T.C.C.)].
3.
The
appellant
is
at
liberty
to
file
a
notice
of
objection
as
permitted
by
subsection
165(1.1)
of
the
Act
to
the
reassessment
resulting
from
this
judgment
restricted,
however,
to
the
issue
of
silviculture
costs
including
the
proper
amount
to
be
added
to
the
cost
of
inventory
or
deducted
in
computing
income.
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