[2005] EWHC 714 (Ch).

Chancery Division.

Park J.

Judgment delivered 20 January 2005.

Capital gains tax – Chargeable gain – Business asset – Roll-over relief – Assessment – Taxpayer initially obtained roll-over relief on disposal of property – Revenue subsequently taking view that part of expenditure not qualifying for relief – Assessment raised more than six years after relevant period – General commissioners upholding assessment - Whether expenditure in question qualifying for relief – Whether negligent conduct justified assessment outside six year time limit – Taxes Management Act 1970, s. 36.

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