MICHELLE McENROE (1) MIRANDA NEWMAN (2) v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2023] UKUT 00255 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Nicholas Aleksander & Judge Phyllis Ramshaw on 18 October 2023
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CAPITAL GAINS TAX – sale of shares – interpretation of share sale and purchase agreement – did FTT make an error of law in not considering working capital adjustment provisions of SPA – disguised attack on factual findings of FTT – appeal dismissed