Chancery Division.

Judgment delivered 22 April 1985.

Capital gains tax – Chargeable gains – Allowable losses – Value of asset becoming negligible – Taxpayer making chargeable gain and allowable loss in 1973–74 – Taxpayer making no claim for allowable loss until 1978 – Successful claim for relief in 1979 – Hearing adjourned for determination of share values – Appeal restored and reopened in 1984 – Appeal determined in favour of Crown after further argument – Whether Commissioners correct to reopen appeal – Finance Act 1965, sec. 23(4) (now Capital Gains Tax Act 1979, sec. 22(2)).

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