|Source:||All England Reporter|
|Publisher Citation:|| All ER (D) 138 (Nov)|
|Court:||Court of Appeal, Civil Division|
Pill, Robert Walker LJJ and Laddie J
|Representation||Leolin Price QC and Evan Price (instructed by Jeffrey Green Russell) for the applicant.|
|Timothy Brennan QC (instructed by the Solicitor of Inland Revenue) for the commissioners.|
|Judgment Dates:||9 November 2001|
Income tax - Charge to tax - Liability - Insurance - Life policy - Qualifying policy - Proceeds of qualifying policy not chargeable to tax - Revenue declining to certify draft policy as qualifying policy - Whether draft policy meeting statutory test for qualifying policy - Whether Revenue having discretion to refuse to certify policy which meets statutory requirements - 15, paras 1, 21.