Decision Number: | TC 08377 |
Appellant: | CHRISTOPHER DRAKE |
Respondent: | Her Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
Zachary CITRON |
Date Of Decision: | 17/01/2022 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | CAPITAL GAINS TAX - agreement for grant of lease on payment of premium - taxpayer paid deposit at time of contract as part payment of premium due on completion - taxpayer defaulted on next stage payment of premium and so contract rescinded - was the lost deposit an allowable loss? - Hardy (Upper Tribunal), Lloyd-Webber (First-tier Tribunal) and Underwood (Court of Appeal) considered - Held: the Tribunal was bound by the decision of the Upper Tribunal in Hardy - appeal dismissed |