Court of Appeal.

Judgment delivered 12 June 1987.

Corporation tax – Chargeable gains – Capital sum derived from asset – Option – Action to enforce option compromised by consent order – Option surrendered in consideration of payment – Whether sum derived from disposal of option or from rights under consent order – Whether abandonment of option – Whether surrender of option constituted disposal – Whether disposal occurred at time of receipt of sum or of making of order – Finance Act 1965, sec. 22(3), Sch. 7, para. 14(3) (now Capital Gains Tax Act 1979, sec. 20(1), 137).

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