1. Christopher John Barry Walls, (the Appellant) appeals against the rejection by the Inspector of Taxes of his claim for loss relief for the years 1990/1991 and 1991/92 arising from his letting of furnished holiday accommodation which if it be ‘the commercial letting’ of such accommodation is by virtue of section 503 Income and Corporation Taxes Act 1988 (‘the Act’) treated as a trade and relief for losses may be claimed accordingly.

2. S 504(2) provides that:

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