Balcombe and McCowan L JJ and Sir Christopher Slade.
Judgment delivered 30 April 1991.
Income tax – Annuity – Deductions in computing total income – Tax avoidance scheme – Covenant by taxpayers to make five annual payments to charity in consideration for capital sum – Capital sum used by taxpayers as security for covenanted payments – Whether payments to be treated as annuities or other annual payments deductible from total income – Income and Corporation Taxes Act 1970, sec. 52(1) (replaced by Income and Corporation Taxes Act 1988, sec. 348(1)).