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United Kingdom House of Lords Decisions
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Inland Revenue Commissioners v Garvin and Rose [1981] UKHL TC_55_24 (14 May 1981)
URL: http://www.bailii.org/uk/cases/UKHL/1981/TC_55_24.html
Cite as:
[1981] TR 215,
[1981] STC 344,
[1981] 1 WLR 793,
55 TC 24,
[1981] UKHL TC_55_24,
[1981] WLR 793
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Inland Revenue Commissioners v Garvin and Rose [1981] UKHL TC_55_24 (14 May 1981)
Income tax and surtax - Transactions in securities - Tax advantage - Counteraction - Sale of shares in property companies - Subsequent payments of abnormal dividends by property companies - Whether relevant circumstances present - Whether sale of shares transactions "whereby" another person received abnormal dividends - Whether purchase price of shares received "in connection with" re-acquisition by vendors of shares of assets of property companies - Whether property companies were at material time companies to which para of s 461 applies - Insufficient evidence in Case Stated - Whether onus on taxpayer or Crown - Whether tax advantages obtained - Income and Corporation Taxes Act 1970, s 460, paras C and D of s 461, proviso to para D(2) ofs 461, s 466 and s 467(2).
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