Court of Appeal (Civil Division).

[The appeal against this decision is reported at [1992] BTC 110.]

Browne-Wilkinson V-C, Stuart-Smith and Leggatt L JJ.

Judgment delivered 30 January 1991.

Corporation tax – First-year allowance – Limited partnership – Taxpayer became limited partner in limited partnership formed to participate in scheme to obtain first-year allowances for master negative of film – Partnership provided 100 per cent of production cost, 75 per cent of which borrowed on non-recourse terms from production company which was to take 75 per cent of any profits – Whether partnership trading – Finance Act 1971, sec. 41(1).

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