[The appeal against this decision is reported at [2006] BTC 866.]

Howard M Nowlan

Decision released 1 June 2006

Income tax – Claim to deduct £200 paid as an exam fee as vocational training relief under s. 32 FA 1991 – alternative claim as a Schedule D Case I expense – whether income or capital expenditure – general claims of unfair treatment – Appeal dismissed


A special commissioner decided that a taxpayer was not entitled to a deduction in respect of the cost of examination re-sit fees, either as vocational training relief or as an ordinary trading deduction.


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