The appeal

1. Sycamore Plc and Maple Ltd (the Appellants) appealed against three decisions made by the Inland Revenue on 28 September 1995. Sycamore Plc (Sycamore) appealed against a decision to refuse a claim to set off losses in one accounting period against profits of an earlier accounting period and also against a decision to refuse a claim to have surplus advance corporation tax in one accounting period treated as if it were advance corporation tax paid in respect of distributions made in the previous accounting period. Maple Ltd (Maple) appealed against a decision which disallowed a claim for group relief in respect of trading losses surrendered by Sycamore.

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