Chancery Division.

[The appeal against this decision is reported at [1986] BTC 455.]

Judgment delivered 28 February 1985.

Corporation tax – Trade – Trading losses – Loss relief – Taxpayer company entering into contract for sale of factory – Liquidation of company before completion – Inability of purchaser to complete – Scheme devised whereby purchaser assigned contract rights to off-the-shelf company acquired by taxpayer company which sold to new purchaser – Whether sale of factory under original contract – Whether taxpayer entered into preordained series of transactions to avoid tax – Finance Act 1971, Sch. 10, para. 10(1).

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