The British Olympic Association (‘BOA’) appeals against four assessments to Corporation Tax for the accounting periods ended 31 December 1990, 31 December 1991, 31 December 1992 and 31 December 1993.

The agreed questions for determination are:–

(a)whether BOA is carrying on any, and if so what, trade;

(b)whether, on the basis that the trade can be identified, the expenses incurred by BOA in conducting its activities are deductible in full or in part in computing the profits of any such trade.

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