Mr THK Everett sitting in Edinburgh.

Decision released 23 May 1995.

Income tax – Sch. E – Foreign earnings of seafarer – Absence from UK – In 1987–88 the taxpayer worked outside the UK for two periods separated by 81 days – Whether entitled to relief under new provisions – The new provisions did not take effect until 1988–89 – Appeal dismissed – Finance Act 1988, s. 67(2).

C Cairns, chartered accountant of Downie Wilson, for the taxpayer.

TM Ellis, inspector of taxes.


Mr Ian Craig Massey (‘the taxpayer’) appeals against an assessment to income tax under Schedule E for 1987/88 in the sum of £20,915.

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