Colin Bishopp

Decision released 13 October 2003

Income tax – filling station proprietors – fuel company providing funds as a ‘ contribution towards the operating costs of your business’ – part of funds used to finance purchase of business – payments made to taxpayers' solicitors for use in purchase – whether income or capital receipt – whether undifferentiated payment – error or mistake relief refused – relevant payment found to be capital receipt – appeal allowed – Taxes Management Act 1970, s. 33.

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