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Appeal allowed in part. 1 Transcript, pages 40 — 43 and 110 & 111; Exhibit P-5. 2 15. (1) Where in a taxation year... ...

HI — PART XIII — 1. All the following: (a) machinery and apparatus sold to or imported by manufacturers or producers for use by them directly in (i) the manufacture or production of goods The Issue In essence, then, the only issue is whether the pipelines are used directly in the production of saleable components of natural gas liquid which components, it was agreed, are propane, iso-butane, normal butane and pentanes plus. ...

Thus, § 7601 gives the Internal Revenue Service a broad mandate to investigate and audit "persons who may be liable” for taxes and § 7602 provides the power to "examine any books, papers, records, or other data which may be relevant... ...

A court should ask — what would the words of the statute be reasonably understood to mean by those governed by the statute? ... Appeal dismissed. 1 “In Turgeon v The Dominion Bank, [1930] S.C.R. 67 at p 71, Newcombe J noted that the maxim “... no doubt has its uses when it aids to discover intention; but, as has been said, while it is often a valuable servant, it is a dangerous master to follow. ...

.: — This is an appeal from a decision of the Tax Court of Canada. Succinctly stated, the issue to be decided is whether a lump sum payment received by the appellant taxpayer, an American citizen and resident of Canada, is exempt from taxation in Canada by reason of the Canada-United States Income Tax Convention (1980), as amended (the “Convention”). ... (Release no. 84-128 Aug. 16/1984) The view has been expressed elsewhere that as a result of the Department of Finance’s endorsement, the Technical Explanation constitutes either an agreement or instrument within Article 31(2)(a) or (b) of the Vienna Convention or a subsequent agreement within Article 31(3)(a), rather than a supplementary means of interpretation within Article 32 of the Vienna Convention: see The Partners of Davies, Ward & Beck and Brian J. ...

.: — This is an appeal from a judgment of the Trial Division, pronounced on May 18, 1995, which set aside a determination by the Minister of National Revenue that excise tax paid by the respondent, Canadian Turbo, on the sale of gasoline and diesel fuel was not refundable. ... (London: Sweet & Maxwell, 1977); Bryan A. Garner, A Dictionary of Modern Legal Usage, 2nd ed. ...

It appears to me that whether that submission accurately characterizes the 1963 agreement or not — and I am not inclined to regard it as an inaccurate characterization — what must be determined is not so much the substance or character of the agreement itself, but the nature of what has accrued to the appellant under it. ...

Culver himself was very directly on point in his expert report (Appeal Book, appendix /, at page 6): Faced with a choice between the alternative of accruing or not accruing the unbilled income, I would opt for the former. ... Kohler, in A Dictionary for Accountants, 1957 edition, page 408, defines it as “ collectible, whether or not due. ... Gardner Mountain & D'Anbrumenil, Ltd. (1947), 29 T.C. 69, at page 93 was willing to accept "an estimate of what the future remuneration will amount to" and even "a discounting of the amount to be paid in the future.” ...

The most practicable kind of legal definition would appear to be that actually used in subparagraph (D) of (ii), a well that “... will not come into production in commercial quantities wtihin twelve months of its completion.” ... Per: A R McPhee (signed) APPENDIX I DOME CZAR ET AL WEALD 6-11-5221 W5M Services Included in Turnkey Price and to be provided by Contractor Rig and Camp and Move Drilling — footage Drilling — daywork Mud and Chemicals Water Equipment Rentals Coring Testing D S T Logging Surface Casing Cementing Abandonment Service or Production Casing Cementing Camp and Crew Travel My interpretation of this contract is that the payment of $460,000 was for the materials, supplies and services provided for in Appendix I which was thought to be a relatively certain amount, and for other services, materials, equipment and supplies, which was thought to be a somewhat uncertain amount. ...

Langan, Snell’s Principles of Equity (London: Sweet & Maxwell, 1982) at 41. ... This Part as it relates to matters preliminary to the issue of the letters patent and supplementary letters patent are directory only; and no letters patent, or supplementary letters patent, issued under this Part shall be held void for any irreg- ularity, insufficiency or want of compliance herewith as respects such preliminary matter, … This section does not help the appellants. ... First, I am of opinion that the phrase “consideration that includes shares, ” in its plain and ordinary meaning, cannot refer to consideration that consists of a simple promise to issue shares. ...