House of Lords.

Judgment delivered 31 January 1985.

Corporation tax – Trading stock – Groups of companies – Dealer in shares and securities – Acquisitions of shares and debt from parent company – Conversion of capital loss to trading loss – Tax avoidance – Finance Act 1965, Sch. 7, para. 1Income and Corporation Taxes Act 1970, sec. 274.

  This was an appeal by the Crown from a decision of the Court of Appeal in the taxpayer’s favour that it was open to the General Commissioners to conclude that certain shares and debts had been acquired by the taxpayer ‘as trading stock’.

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