Jenkinson (H.M. Inspector of Taxes) v Freedland(1) (1958-1961) 39 TC 636
HIGH COURT OF JUSTICE (CHANCERY DIVISION)–
17TH NOVEMBER, 1960
COURT OF APPEAL–
14TH AND 15TH JUNE, AND 4TH JULY, 1961
Income Tax, Schedule D – Purchase and sale of stills – Whether adventure in the nature of trade.
In 1951, the Respondent, who had a controlling interest in two companies, purchased, for £80 each, two metal stills, the surfaces and moving parts of which were covered with a thick coating of a sticky and highly inflammable resinous substance. He succeeded in removing this substance, put the stills into working order and then sold them, one to each of the companies under his control, for £3,750 each.
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