Chancery Division.

[The appeal against this decision is reported at [1985] BTC 3.]

Judgment delivered 18 November 1983.

Corporation tax – Stock in trade – Stock relief – Whether certain properties fell to be treated as stock in trade – Finance Act 1976, sec. 37; Sch. 5, para. 29.

  This was an appeal by the Crown from a decision of the Special Commissioners that old, as opposed to newly built, properties owned by the company were stock in trade although the aggregate of the values apportioned to the gardens was excluded from stock relief.

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