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M Howes v HMRC

In M Howes v HMRC (TC01874 – 22 March) a surveyor (H) purchased a herd of deer in 1990. He disposed of the deer in 2004. In 2002 he claimed that he had made losses in a trade of deer farming which should be set against his income as a surveyor. Following an enquiry HMRC issued a closure notice stating that the restriction laid down by what is now ITA 2007 s 67 applied and that no loss relief was due for 1996/97 and subsequent years. The First-tier Tribunal dismissed H’s appeal against the notice finding that the farming trade had never been profitable so that ‘the restrictions on the use of farming losses therefore apply for the tax year 1996/97 and subsequent years’.

Why it matters: ITA 2007 s 67 provides that if a loss is...

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