Court of Appeal.

Judgment delivered 13 October 1986.

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

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