| Director General | |
| Financial and Corporate Analysis Division | |
| Energy, Mines and Resources Canada | File No. 5-9213 |
| 7th Floor, 460 O'connor Street | G.R. White |
| Ottawa, Ontario | (613) 957-8585 |
| K1A 5H3 |
Attention: Mr Donald G. Schell Director Mining Tax Legislation Interpretation Division
January 3, 1990
Dear Sirs:
Re: 24(1) Mineral Resource Subsection 248(1) of the Income Tax Act
We are writing to request your certification 24(1) is a mineral resource as that term is defined in subsection 248(1) of the Income Tax Act.
A copy of our letter from the taxpayer's consulting geologist is attached. We have contacted him and explained that his request for a ruling on the eligibility of exploration expenses under the CEIP program cannot be answered by this Department since CEIP is administered by Energy, Mines and Resources Canada. We have given him the address of your Director of Interpretations and Rulings. He told us that he had sent the same package of material to each Department.
Yours truly
Director GeneralRulings DirectorateLegislative and Intergovernmental Affairs Branch