Chancery Division.

Judgment delivered 9 November 1982.

Capital gains tax – Asset becoming of negligible value in 1973/74 – Claim for notional loss made in 1977/78 – Whether notional loss can arise before date of claim – Finance Act 1965 – sec. 23(4) – (See now Capital Gains Tax Act 1979, sec. 22(2)).

  This was an appeal by the Crown from a decision of the General Commissioners.

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