COURT OF SESSION (FIRST DIVISION)–

1ST, 2ND AND 23RD JUNE 1971

Corporation tax – Chargeable gains – Allowable loss – Investment company – Loan to trading company in anticipation of acquiring controlling interest therein – Loan irrecoverable on liquidation of trading company – Whether loss of debt or of rights to allotment of shares – Whether ‘debt on a security’ – Finance Act 1965 (c.25), ss.22, 23 and 55 and Sch. 7, paras. 5 and 11(1).

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