Roger Dyer and Jean Dyer v The Commissioners for HM Revenue and Customs: [2016] UKUT 0381 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Bishopp and Judge Raghavan on 2 September 2016.
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.INCOME TAX and CAPITAL GAINS TAX — negligible value claim — TCGA 1992 s 24(2) — whether shares were already of negligible value at acquisition — whether First-tier Tribunal’s affirmative conclusion undermined by its overlooking paragraph of statement of agreed facts — no — finding of negligible value on acquisition fully justified — appeal dismissed