John Lewis Properties plc v Inland Revenue Commissioners.  BTC 127
 EWCA Civ 1869.
Court of Appeal (Civil Division).
Schiemann, Arden and Dyson L JJ.
Judgment delivered 20 December 2002.
Corporation tax – Receipt – Income or capital – Rent factoring scheme – Taxpayer owned properties let to ultimate group holding company – Assignment of future rent in return for discounted lump sum – Whether payment was income or capital receipt – Taxation of Chargeable Gains Act 1992, s. 175.