Chancery Division.

Pumfrey J.

Judgment delivered 11 February 1999.

Income tax – Beneficial loan to director – Service company incorporated to pay day to day outgoings of taxpayer’s estate agency business for a cost plus fee – No written agreement but the taxpayer made payments on an ad hoc basis, adjusting the amount when the business’s accounts were made up – Whether credit granted to taxpayer by company and if so whether taxpayer entitled to relief for years during which taxpayer traded in partnership – Income and Corporation Taxes Act 1988, s. 160(1), 353, 367.

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