Chancery Division.

Judgment delivered 1 November 1982.

Receipts from land from licensees – Whether taxpayer company is an investment company or a trading company – Whether taxpayer company retains ‘occupation’ by not granting exclusive possession – Whether management activities may constitute trading – Income and Corporation Taxes Act 1970 – Sch. A (sec. 67); Sch. D, Case I (sec. 109); sec. 110(3); 130(a); 304(5).

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