Chancery Division.

Chadwick J.

Judgment delivered 18 November 1992.

Corporation tax – Capital loss relief – Loans guaranteed by taxpayer company – Cross guarantees between taxpayer and ten other group members – Loans to two companies called in by bank – Payment of whole debt under guarantee made by taxpayer – No steps taken to recover from co-guarantors – Whether relief available in respect of whole amount paid under guarantee or part or none – Capital Gains Tax Act 1979, sec. 136(4) (replaced by Taxation of Chargeable Gains Act 1992, sec. 253(4)).

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