Mr THK Everett.

Decision released 21 October 1997.

Income tax – Partnership – ‘Salary’ paid to one of the partners – Resulting loss – Whether loss relief available in assessing the partners’ tax liability – Appeal dismissed.


The issue was whether loss relief was available in respect of salaries paid to two partners.

PDC Copyprint (South) (‘the partnership’) was established as a partnership of Mr Marks, Mr Ricketts and Mr Jones on 13 January 1986. Mr Marks resigned on 1 May 1989 and was replaced by his wife, with the agreement of the other continuing partners.

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