The tax exemption of surpluses from mutual business does not affect the deductibility of a contribution in computing the profits of the contributor, where the contributions satisfies all other requirements applicable to expenses (Thomas v Richard Evans & Co Ltd (1927) 11 TC 790; see ¶707-150ff.). This is so even where parts of the contribution is accumulated as a surplus and may be returned to the contributor in certain circumstances. In such circumstances the contributor has:

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