Roger Dyer and Jean Dyer v The Commissioners for HM Revenue and Customs

JurisdictionUK Non-devolved
JudgeJudge Bishopp,Judge Raghavan
Neutral Citation[2016] UKUT 0381 (TCC),[2016] UKUT 0381 (TCC)
CourtUpper Tribunal (Tax and Chancery Chamber)
Date02 September 2016
Subject MatterTax,2 September 2016
Published date15 February 2017
[2016] UKUT 0381 (TCC)
INCOME TAX and CAPITAL GAINS TAX — negligible value claim — TCGA
1992 s 24(2) — whether shares were already of negligible value at acquisition —
whether First-tier Tribunal’s affirmative conclusion undermined by its overlooking
paragraph of statement of agreed facts — no — finding of negligible value on
acquisition fully justified — appeal dismissed
UPPER TRIBUNAL
TAX AND CHANCERY CHAMBER Appeal No: UT/2015/0086
BETWEEN:
ROGER DYER and JEAN DYER Appellants
and
THE COMMISSIONERS FOR HER MAJESTY’S
REVENUE AND CUSTOMS Respondents
Tribunal: Judge Colin Bishopp
Judge Swami Raghavan
Sitting in public in London on 23 May 2016
Mr Roger Dyer, assisted by Mr Gordon Lowthian, appeared for both appellants
Miss Hui Ling McCarthy, counsel, instructed by the General Counsel and Solicitor
to HM Revenue and Customs, for the respondents
CROWN COPYRIGHT © 2016

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