[2012] UKUT 278 (TCC);

[2012] UKUT 279 (TCC).

Upper Tribunal (Tax and Chancery Chamber).

[The appeal against this decision is reported at [2014] BVC 42.] [See also related decision reported at [2012] BVC 1,939 and [2015] BVC 501.]

Warren J, Judge Charles Hellier.

Decision released 3 August 2012.

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