Upper Tribunal (Tax and Chancery Chamber).

Arnold J.

Decision released 11 March 2011.

Corporation tax – Trading profits – Customers' unreconciled payments – Unreconciled amounts transferred to balance sheet account and released to profit and loss account at financial year-end – Legal status of mistaken payments from customers – Whether payments constituting trading receipts accruing or arising from trade for tax purposes – Taxpayer’s appeal dismissed – Income and Corporation Taxes Act 1988, s. 18(1)(a)(ii).

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