W.A. & F. RUTHERFORD v COMMISSIONERS OF INLAND REVENUE (1938-1941) 23 TC 8
NO. 1123–COURT OF SESSION (FIRST DIVISION)–
13TH AND 14TH JUNE AND 13TH JULY, 1939
Income Tax, Schedule D – Deduction from profits – Solicitors acting also as insurance agents, factors and stockbrokers – Loss of money lent to clients.
The Appellants carried on business as Writers to the Signet but also acted as factors, insurance agents and stockbrokers. They did not hold themselves out as financiers or money-lenders but they were in the habit of making advances to clients. Such loans had always arisen directly out of the Appellants’ general legal or other business.