In PG Donaghy v HMRC (Upper Tribunal – 11 May) a farmer (D) made a trading profit of £20 244 in 2005/06 and a trading loss of £10 315 in 2006/07. He claimed that the profit of these two years should be averaged under ITTOIA 2005 s 221. HMRC issued a ruling that the result of this claim was that D had taxable profits of £10 122 for 2005/06 and that £10 122 of the trading loss could be set against the averaged profit of £10 122 for 2006/07 leaving a small loss of £193 to be carried forward to 2007/08. D appealed contending that as his total profit for the two years had been £9 929 he should be treated as having a taxable profit of £4 964.50 for each of 2005/06 and 2006/07. The Upper...
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In PG Donaghy v HMRC (Upper Tribunal – 11 May) a farmer (D) made a trading profit of £20 244 in 2005/06 and a trading loss of £10 315 in 2006/07. He claimed that the profit of these two years should be averaged under ITTOIA 2005 s 221. HMRC issued a ruling that the result of this claim was that D had taxable profits of £10 122 for 2005/06 and that £10 122 of the trading loss could be set against the averaged profit of £10 122 for 2006/07 leaving a small loss of £193 to be carried forward to 2007/08. D appealed contending that as his total profit for the two years had been £9 929 he should be treated as having a taxable profit of £4 964.50 for each of 2005/06 and 2006/07. The Upper...
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