Chancery Division.

Judgment delivered 11 November 1981.

Corporation tax – Deduction of bank interest – Property dealing company – Loan obtained to purchase property for dealing – Property rented in the meantime – Whether interest to be deducted from dealing profits under Case I of Sch. D or from total profits – Carry forward of losses from dealing activities – Income and Corporation Taxes Act 1970 – sec. 248; 250; 251; Sch. A and Sch. D, Case I.

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

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