[2008] EWHC 2720 (Ch).

Chancery Division.

[The appeal against this decision is reported at [2010] BTC 398.]

Lewison J.

Judgment delivered 11 November 2008.

Corporation tax – Capital gains – Tax advice – Negligence – Accountant – Duty of care – Roll-over relief on reinvestment – Subsidiaries – Hiving up – Goodwill – Defendant accountants giving tax advice to claimants – Claimants seeking damages for negligence – Defendants seeking summary judgment – Whether defendants owing duty of care to first claimant – Whether claims statute-barred.

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