Queen’s Bench Division (Crown Office List).

[The appeal against this decision is reported at [1987] BTC 8024.]

Judgment delivered 8 July 1986.

Stamp duty – Merger of companies – Share swop scheme – Allotment of shares – Multiple allotment fulfilling requirement for duty exemption – Whether earlier allotments exempt – Revenue practice in relation to exemption – Whether taxpayer company entitled to discovery of documents relating to alleged Revenue practice and alleged assurance by Revenue that practice existed – Finance Act 1973, Sch. 19, para. 10

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