Chancery Division.

[The appeal against this decision is reported at [1984] BTC 424.]

Judgment delivered 11 November 1983.

Income tax – Relief – Trading losses – Limited partnership – Whether taxpayer entitled to allowance for 95 per cent of agreed losses – Whether taxpayer entitled to allowance of only 10 per cent of losses – Income and Corporation Taxes Act 1970. sec. 168.

  This was an appeal by the Crown against a determination of the Special Commissioners that the taxpayer was entitled to loss relief of £41,423, her agreed share of the losses sustained by a partnership, to be set off against her general income.

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