Mr DA Shirley.

Decision released 14 December 1995.

Income tax – Payments from foreign source – Taxpayer was employee of French company who worked and lived in France – Taxpayer made redundant before 60th birthday and returned to live in UK – Periodical payments in respect of redundancy until the age of 65 – Whether payments were income or instalments of capital for the sterilisation of capital asset, i.e. capacity to work – Payments were income – Appeal dismissed – Case V of Sch. D.

Hugh McKay, instructed by FW Stephens & Co, chartered accountants, for the appellant.

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