The Law Reports (Appeal Cases)
[1975] AC 38
[HOUSE OF LORDS]
INLAND REVENUE COMMISSIONERS APPELLANTS AND MILLS RESPONDENT
[On appeal from MILLS v. INLAND REVENUE COMMISSIONERS]
1973 Nov. 22,
26,
27,
28;
1974 Feb. 12
1974 Feb. 12
Lord Reid, Lord Morris of Borth-y-Gest, Lord Hodson, Viscount Dilhorne and Lord Salmon
Revenue
— Surtax
— Settlement
— Company employing infant taxpayer at nominal salary
— Large profits earned by providing taxpayer's services
— Dividends paid to trustees of settlement of which taxpayer beneficiary
— Whether taxpayer “settlor”
— Whether taxpayer provided funds for “purpose” of settlement
—
Income Tax Act 1952 (15 & 16 Geo. 6 & 1 Eliz. 2, c. 10), ss. 405 (1), 409, 411 (2)