The appellant submits that he should be entitled to apply $25,780.47 in 2006 and $6,698.53 in 2007. The respondent submits that the appellant must apply $29,521.31 in 2006 and $2,957.69 in 2007. The issue has no effect on the tax payable for the 2006 taxation year since there is no tax payable for that year under either scenario. The issue only affects tax payable for the 2007 taxation year. The relevant legislative provision is section 118.61 of the Act, [paragraph 4 of decision] which is as it was in effect for 2007. The interpretation of the Act is not in dispute. What is the issue with Schedule 11? (paragraphs 6-10 of the decision)