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.”, and further must reasonably be regarded as “... having been received... in consideration or partial consideration...” for the covenants not to compete.* [1] The appellant, on the other hand, asserts that on the true construction of the material documents, particularly the notarial deed, the transaction in question was fundamentally a sale of assets: the shares and whatever other interests Louis and Harry had in the four companies, their rights to carry on a bakery business for 25 years, and their rights to the use of the name Richstone in any business (see clauses first, second, third and fourth of the notarial deed) for 25 years. ...

& Mary, sess 2, c. 2) s.1 Article 9 prohibits impeaching or questioning proceedings in Parliament. ...

It was stated in this way by Parke, B (Becke v Smith (1836), 2 M & W 191 at p 195): “It is a very useful rule, in the construction of a statute, to adhere to the ordinary meaning of the words used, and to the grammatical construction, unless that is at variance with the intention of the legislature, to be collected from the statute itself.” ...

The situation is almost identical to that considered in the case of Greig (Inspector of Taxes) v Ashton, [1956] 3 All ER 123 at 125, where Harman, J stated: The portion of the convention providing for double taxation relief with the United States appears in the Schedule to the Double Taxation Relief (Taxes on Income) (USA) Order, 1946 (SR & C 1946 Nc 1327), of which art XIII(2) provides: “Subject to such provisions... as may be enacted in the United Kingdom, United States tax payable in respect of income from sources within the United States shall be allowed as a credit against any United Kingdom tax payable in respect of that income.’’ ...

Another expedient to indicate a plurality of members would be to adopt a style such as: “Cornforth & Co” or “Cornforth and Associates”. ...

.: — Relief Requested This is an application by the Minister of National Revenue under subsection 174(1) of the Income Tax Act, R.S.C. 1952, c. 148 (am. ...

By Interpretation Bulletin IT-368 dated March 28, 1977 and entitled, “Corporate Distributions — Clearance Certificates” a wide application is given to subsections 159(2) and (3) by the Minister, Paragraphs 1, 2 and 3 of that Bulletin are those relevant in this matter. ...

In this connection Defendant refers to the judgment of the Court of Appeal in the as yet unreported case of The Clarkson Company Limited, the Receiver and Manager of the property and undertaking of Rapid Data Systems & Equipment Limited v Her Majesty The Queen, No A884-77 a judgment dated April 18, 1978, [1979] CTC 96. ...

The case therefore turns, as Addy, J put it in D P McLaws v The Queen, [1976] CTC 15 at 16: 76 DTC 6005 at 6006, “... entirely on the interpretation to be given to those facts and on the conclusions of fact to be drawn therefrom.. ...

On this see L Berman & Co Ltd v MNR, [1961] CTC 237; 61 DTC 1150, per Thorson, P at page 247 [1156]: There is no doubt in my mind that the appellant made the payments in question as a business person intending to continue in business would reasonably do and that consequently, they were made in accordance with the ordinary principles of commercial trading or well accepted principles of business practice and I am unable to find any ground in Section 12(1)(a) for their exclusion. ...