In Mr and Mrs Scambler v HMRC [2016] UKFTT 47 (26 January 2016) the FTT denied sideways loss relief to a farm (ITA 2007 ss 67 and 68).
Mr and Mrs Scambler ran a farm. The milk produced was sold under an exclusive contract to Dairy Crest under which Dairy Crest could change the price paid for milk on one month’s notice.
Referring to French [2014] UKFTT 940 the FTT noted that the activities covered by s 68(3)(b) were the activities carried on by Mr and Mrs Scambler in 2005 the start of the loss period. Furthermore the test in s 68(3)(b) was set out in two stages; there had to be evidence both of competence and of the reasonableness of the profit expectation. The question was therefore whether it had been reasonable for Mr and Mrs Scambler ...
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In Mr and Mrs Scambler v HMRC [2016] UKFTT 47 (26 January 2016) the FTT denied sideways loss relief to a farm (ITA 2007 ss 67 and 68).
Mr and Mrs Scambler ran a farm. The milk produced was sold under an exclusive contract to Dairy Crest under which Dairy Crest could change the price paid for milk on one month’s notice.
Referring to French [2014] UKFTT 940 the FTT noted that the activities covered by s 68(3)(b) were the activities carried on by Mr and Mrs Scambler in 2005 the start of the loss period. Furthermore the test in s 68(3)(b) was set out in two stages; there had to be evidence both of competence and of the reasonableness of the profit expectation. The question was therefore whether it had been reasonable for Mr and Mrs Scambler ...
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