Court of Appeal.

[The appeal against this decision is reported at [1984] BTC 49.]

Judgment delivered 25 March 1983.

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.

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