[The appeal against this decision is reported at [1996] BTC 416.]


Mr Mark Stephen Jacobs appeals against an assessment to income tax under Schedule E for the year 1991/92. That assessment encompasses a variety of sources of income but the only one which is the subject of dispute is an amount of £20,908 paid by City Electrical Factors Ltd (‘CEF’) to Charles Grosvenor Construction Ltd (‘the builders’) for the construction of a loft conversion at Mr Jacobs’ house at 45 Cissbury Ring North, London N12. That sum has been assessed by the Inspector as a benefit in kind pursuant to section 154 Income and Corporation Taxes Act 1988.

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