Chancery Division.

[The appeal against this decision is reported at [1987] BTC 83.]

Judgment delivered 3 March 1986.

Income tax – Schedule E – Emoluments – Employment – Changes in conditions of service – Ex gratia payment by employer in recognition of loss of rights as employee – Whether payment was emolument from employment – Whether payment was benefit of higher-paid employee – Income and Corporation Taxes Act 1970. sec. 181(1), 183(1); Finance Act 1976, sec. 61(1).

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