Mr DA Shirley.

Decision released 25 May 1995.

Corporation tax – Surplus advance corporation tax – Claim to set off surplus against earlier periods – Whether company had an accounting period 31 March 1991 to 31 March 1992 during which dividend paid – Company had ceased trading when its only customer went out of business in March 1991 – Company had no source of income and no accounting period at relevant time – Appeal dismissed – Income and Corporation Taxes Act 1988, s. 12, 239(3).

Mr Richard Citron of BDO Stoy Hayward for the company.

The inspector appeared in person.

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