[14 May 1992]

1. Section 35(6) TCGA 1992 (Section 96(6) FA 1988) provides that an election under Section 35(5) (Section 96(5)) of that Act should be made within two years of the end of the year of assessment or accounting period in which “the first relevant disposal” is made, or such longer period as the Commissioners for Her Majesty's Revenue and Customs may allow.

2. The Board [Commissioners for Her Majesty's Revenue and Customs] will always exercise their discretion to extend the time limit to at least the date on which the statutory time limit would expire if disposals of a certain kind did not count as a first relevant disposal of either

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