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Philip John Underwood v. The Commissioners for Her Majesty’s Revenue and Customs – Special Commissioners

CAPITAL GAINS TAX – time of disposal – sale of land – Appellant contracted to sell land and on same day purchaser gave Appellant option to re-purchase – before sale to original purchaser completed Appellant exercised option to re-purchase – Appellant then contracted to sell to a company connected with Appellant – only transfer executed by Appellant was transfer to connected company – whether a disposal of land to, and acquisition by, original purchaser – no – if so, whether date of disposal and acquisition of land for purposes of capital gains tax was date of contract to sell to original purchaser as argued by Appellant – no –appeal dismissed – TCGA 1992 s 28

Patrick Soares and Hui Ling McCarthy appeared for the Appellant

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