Dr John F Avery Jones, John Clark.

Decision released 13 January 2003.

Corporation tax – Losses – Trading stock – Parent company decided to sell portfolio of investment properties – Properties owned by investment subsidiaries transferred to taxpayer as property dealing member of group – Whether properties in course of sale by group investment companies acquired by taxpayer as trading stock – Taxation of Chargeable Gains Act 1992, s. 161(3), 173(1).

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