Martin Francis George (‘Mr George’) appeals against an assessment to Income Tax under Schedule E for 1987/88 in sum of £138,500.

Mr George was dismissed from his employment and received in January 1988 a termination payment which included, in addition to a cash sum, the right to use for a period of nine years, a succession of motor cars provided by his former employer. The dispute before me concerns the chargeability as an emolument of the car provision pursuant to section 187(3) Income and Corporation Taxes Act 1970. That Act was the statute in force at the relevant time and statutory references in this Decision are to that Act unless otherwise stated.

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