Chancery Division.

Judgment delivered 12 May 1986.

Corporation tax – Sch. D. Case I – Losses – Investment company – Loans acquired from banking company and realised income at a loss – Whether company carried on trading activity – Whether secured loans were trading stock – Whether trading loss – Whether company entitled to group relief – Income and Corporation Taxes Act 1970, sec. 109, 130(a),258.

  This was an appeal by the taxpayer companies against a decision of the General Commissioners for Central Manchester that they were not entitled to group relief in respect of losses incurred in realising loans.

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