[2004] EWHC 1069 (Admin).

Queen’s Bench Division (Administrative Court).

Moses J.

Judgment delivered 2 March 2004.

Capital gains tax – Judicial review – Interest in possession in settlement – Sale of shares and loan notes – Whether loan notes qualifying corporate bonds – Appeal to special commissioners – Taxpayer sought judicial review on basis that Revenue had taken no action in relation to other taxpayers in similar position – Taxation of Chargeable Gains Act 1992, s. 115.

  This was an application for permission to move for judicial review by a taxpayer who had been assessed to capital gains tax.

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