Queen’s Bench Division.

[The appeal against this decision is reported at [1990] BTC 352.]

Judgment delivered 7 December 1987.

Income tax – Sch. D – Trade – Taxpayer carrying on business as prostitute – Provision of services for customer for reward – Whether Revenue acted ultra vires in raising assessment to tax on profits of prostitution – Whether prostitution could be regarded as trade – Whether taxpayer entitled to raise defence after appeal settled by agreement – Taxes Management Act 1970, sec. 54, 118; Rules of the Supreme Court, O. 14.

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