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Decision Number: |
TC 00156 |
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Appellant:
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Ernest Burton Ernest Floate David Leech Gordon Pirret Davendra Pratap Terry Simpson |
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Respondent:
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Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
Adrian J SHIPWRIGHT
W Theodore O WALLACE
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Date Of Decision:
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16/07/2009 |
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Main Category:
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CAPITAL GAINS TAX/TAXATION OF CHARGEABLE GAINS |
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Main Subcategory:
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Trusts |
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Notes:
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CAPITAL GAINS TAX – ss 86, 87, 90, 97 and Schedule 5 TCGA -“Flip Flop”- whether taxpayer still interested within s.86(1)(d) in first settlement from which he was excluded because money borrowed by first settlement settled on second settlement? No – Whether taxpayer regarded as receiving capital payment within s.87(4) when money transferred to second settlement? Yes – Whether outright payment of money within s.97(4)? Yes – Appeal allowed in part
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Decision(s) to Download:
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TC00156.doc 
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