Chancery Division.

[The appeal against this decision is reported at [1990] BTC 552.]

Vinelott J.

Judgment delivered 20 November 1989.

Income tax – Benefits in kind – Education – Sons of schoolmasters employed by independent school provided with places at 20 per cent of normal fees – Whether cost of benefit to employer marginal cost of items attributable to individual pupil such as food, stationery etc. or full cost of running school divided by total number of pupils – Finance Act 1976, sec. 61(1), 63(1), (2) (now Income and Corporation Taxes Act 1988, sec. 154(1), 156(1), (2)).

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