A reserve which the taxpayer had erroneously deducted from income in his 1984 taxation year (which now was statute-barred) was required to be included in income for his 1985 taxation year. Mogan TCJ. stated (p. 1257):
"... if a reserve is in fact claimed and allowed in a particular taxation year, the legality of the allowance is not material and the amount that was in fact deducted must be included in computing the income for the immediately following year".