Court of Appeal (Civil Division).

Balcombe, McCowan and Rose L JJ.

Judgment delivered 18 May 1994.

Corporation tax – Close company – Distributable income to be apportioned among participators – Loan repaid by close company – Whether debt incurred for first business undertaking or property of a substantial character in fact acquired by the company – Whether question of law or of fact – Finance Act 1972, Sch. 16, para. 12(1)(a)(i)(ii) (replaced by Income and Corporation Taxes Act 1988, Sch. 19, para. 8(1)(a) (i)(ii), repealed by Finance Act 1989, s. 103, 187 and Sch. 17, Pt. V).

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