Chancery Division.

Hoffmann J.

Judgment delivered 5 December 1991.

Income tax – Liability for tax on exercise of option granted to employee under company scheme – Election to pay tax in five yearly instalments – All Sch. E emoluments and reliefs assessed in one assessment resulting in a liability less than amount attributable to option gain – Whether taxpayer entitled to pay whole amount of option liability in instalments or only net amount assessed – Finance Act 1982, sec. 40(1)(c) (as amended by Finance Act 1984 and replaced by the Income and Corporation Taxes Act 1988, sec. 137(1)(c)).

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