Chancery Division.

[The appeal against this decision is reported at [1987] BTC 8,029.]

Judgment delivered 7 December 1984.

Corporation tax – Chargeable gains – Unincorporated association – Disposal of land by trustees of sports club – Whether club an entity of assessment for capital gains tax purposes – Whether a person to whom chargeable gains could accrue – Interpretation Act 1889, sec. 1, 19Finance Act 1965, sec. 19, 22(5) (now Capital Gains Tax Act 1979, sec. 1, 46(1)) – Income and Corporation Taxes Act 1970, sec. 238, 265.

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