This is an appeal by the Westbourne Supporters of Glentoran Club (‘the Club’) against assessments to Corporation Tax for the annual accounting periods ending 5 April 1989 and 5 April 1991. The amounts of tax payable under the assessments are £8,750 and £16,138.05 respectively. In each year the total profits chargeable included small amounts of income derived from Sch.A and Sch.D, Case III sources: they are not in dispute. The question before me relates to amounts claimed by the Crown to be taxable as trading profits within the scope of Sch.D, Case I.

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