Chancery Division.

Carnwath J.

Judgment delivered 25 November 1994.

Income tax – Sch. E – Ex gratia payment by parent company of group after taxpayer’s employing company had been sold – Payment made in recognition of loss of option rights – Whether payment taxable – Income and Corporation Taxes Act 1970, s. 181(1); Finance Act 1976, s. 61(1) (Income and Corporation Taxes Act 1988, s. 19(1) and 154(1)).

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