Chancery Division.

[The appeal against this decision is reported at [1984] BTC 164.]

Judgment delivered 15 April 1983.

Income tax – Artificial transactions in land – Gains from land sales by Guernsey companies – Taxpayer providing the opportunity of realising those gains – Basis for valuing gains – Bulk of purchase price deposited with third party and subject to forfeiture in certain circumstances – Whether gain to be calculated on amount received in tax year – Whether sale for money or money’s worth – Income and Corporation Taxes Act 1970, sec. 488(8); 489(13).

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