The Weekly Law Reports
[1987] 3 WLR 660
[COURT OF APPEAL]
CRAVEN (INSPECTOR OF TAXES)
v.
WHITE (STEPHEN)
SAME
v.
WHITE (BRIAN)
INLAND REVENUE COMMISSIONERS
v.
BOWATER PROPERTY DEVELOPMENTS LTD.
BAYLIS (INSPECTOR OF TAXES)
v.
GREGORY
SAME v. SAME AND ANOTHER
1987 Jan. 20,
21,
22,
23,
26;
March 24
March 24
Slade, Parker and Mustill L.JJ.
Revenue
— Capital gains tax
— Tax avoidance
— Negotiations for sale or merger of company
— Taxpayers acquiring shares in non-resident company in exchange for shareholding
— Negotiations concluding with sale of company
— Whether transactions single composite transaction
— Whether “disposal” by taxpayers of shares direct to ultimate purchasers
— Whether relieving provisions for “company amalgamations” applicable to defer liability
—
Finance Act 1965 (c. 25), s. 19(1), Sch. 7, paras. 4(2), 6(1)
Revenue
— Development land tax
— Disposal of land
— Fragmentation of ownership of land prior to sale
— Sale postponed
— Whether eventual sale part of same transaction
—
Development Land Tax 1976 (c. 24), s. 1
Revenue
— Capital gains tax
— Assessment
— Mistake
— Year of assessment wrongly stated
— Taxpayer unaware of error
— Inspector “vacating” assessment without notifying taxpayer
— Whether assessment valid
— Whether mistake to be disregarded
—
Taxes Management Act 1970 (c. 9), s. 114(1)