Colin Bishopp

Decision released 18 October 2004

INCOME TAX — advance corporation tax — purchase by company of its own shares —immediate allotment to vendor shareholder of substantial number of preference shares — contention that majority of preference shares were in reality allotted to shareholder’s daughter not supported by evidence — conditions specified by TA 1988 ss 221, 223 not satisfied — assessments to ACT and income tax on franked income properly made — appeals dismissed

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