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13 December 2005 Internal Memo 2005-0161221A11- interest charged on carry back of loss Unedited CRA Tags 161(1) 161(7) Principal Issues: Whether the comments expressed in our internal memorandum dated May 26, 1998 (our file #9733167) are applicable to the particular fact situation described? ... December 13, 2005 Michael Brescacin, Manager HEADQUARTERS Income Tax, Southern Ontario Region Resources Industry Section Appeals and Referrals Division Income Tax Rulings Directorate Tax & Charities Appeals Directorate Catherine Bowen (613) 957-8284 Attention: John Kingston 2005-016122 Interest payable under subsections 161(1) and (7) We are writing in reply to your electronic transmission dated November 28, 2005 in which you requested our comments on whether the opinion expressed in our memorandum dated May 26, 1998 (our file #E9733167) (the "Opinion Letter") is applicable to a particular fact situation that you are currently dealing with. ...