||All England Reporter
|| All ER (D) 161 (Jan)
||Claire Simpson (instructed by Robinson Barber & Co) for the taxpayer.
||Michael Gibbon (instructed by the Solicitor of Inland Revenue) for the Revenue.
||20 January 2005
Capital gains taxation - Exemptions and reliefs - Roll-over relief - Business asset - Expenditure - Assessment - Assessment that part of expenditure qualifying for roll-over relief - Assessment more than six years after relevant period - Correctness of decision - , s 36.
In the circumstances of the case, the General Commissioners had been entitled to conclude first, that not all of the expenditure in respect of which the taxpayer had claimed roll-over relief for the tax year 1986-1987 did actually qualify for such relief, and secondly, that there had been negligent conduct on the part of the taxpayer or persons on his behalf so as to enable the Revenue to make an assessment more than six years after the relevant period.
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