In S Barker v HMRC (and related appeals) (TC01487 – 24 October) three individuals acquired shares in a company (D) in December 2000 at a total cost of £3 333 333 to each of the three. D subsequently made significant losses and entered a creditors’ voluntary agreement in March 2002. The shareholders subsequently claimed relief under TCGA 1992 s 24(2) on the basis that the shares had become of negligible value by 5 April 2001. HMRC rejected the claims considering that the shares still had some value at that date and the shareholders appealed. The First-tier Tribunal reviewed the evidence in detail and allowed the appeals finding that D had made substantial losses during the first three months of 2001 and concluding that ‘each of the appellants’ shareholdings would in all probability have been...
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In S Barker v HMRC (and related appeals) (TC01487 – 24 October) three individuals acquired shares in a company (D) in December 2000 at a total cost of £3 333 333 to each of the three. D subsequently made significant losses and entered a creditors’ voluntary agreement in March 2002. The shareholders subsequently claimed relief under TCGA 1992 s 24(2) on the basis that the shares had become of negligible value by 5 April 2001. HMRC rejected the claims considering that the shares still had some value at that date and the shareholders appealed. The First-tier Tribunal reviewed the evidence in detail and allowed the appeals finding that D had made substantial losses during the first three months of 2001 and concluding that ‘each of the appellants’ shareholdings would in all probability have been...
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