Court of Appeal.

[The appeal against this decision is reported at [1984] BTC 71.]

Judgments delivered 27 May 1983.

Capital gains tax – Tax avoidance scheme – Relief by deferment – Disposal of assets – Company amalgamations – Shares exchanged – Whether acquiring company controlled company which acquired shares from taxpayers – Whether taxpayers disposed of shares to acquiring company – Finance Act 1965, Sch. 7, para. 4(2), 6(1), (2)Capital Gains Tax Act 1979, sec. 78, 85(1).

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