Income tax – Development gains – Disposal of interest in land – Arrangement to dispose of interest in land – Whether ‘arrangement’ for disposal of interest in land before 18 December 1973 – Whether arrangement evidenced by an adequate written note – What constitutes an adequate note – Finance Act 1974, sec. 38; Sch. 4, para. 4.
This was an appeal by the taxpayers against a decision of Vinelott J. that they were liable to both income tax and capital gains tax on land sold.