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Eugene Blaney v HMRC

In Eugene Blaney v HMRC [2014] UKFTT 1001 (4 November 2014) the FTT held that the taxpayer did not carry on the trade of horse breeding.

Mr Blaney had claimed business asset taper relief from CGT on the disposal of a property but HMRC had restricted the amount of taper relief on the ground that the property had not been a business asset (under TCGA 1992 Sch A1 para 5).

The issue was therefore whether Mr Blaney had used the land for business purposes. This in turn depended on whether his horse breeding activities constituted the carrying of a trade.

The FTT had regard to the various badges of trade identified in Marson v Morton (1986) 59 TC 381. The evidence provided inter alia by Weatherbys (that manages a register of breeders) and the British Horseracing Authority suggested that Mr Blaney had owned neither a broodmare...

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