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Miller's Tales

 
In the first of a series of occasional articles Pete Miller of Ernst & Young's Reorganisations Competency Group writes about some recent tax cases that have taken his interest. This time the theme is capital gains tax
 
Many decisions by the Special Commissioners or the courts go relatively unnoticed by tax practitioners. After all not every case is an Arctic Systems or a BMBF! But some of these more minor cases are nevertheless interesting and I hope readers will agree that each of the cases discussed in this article has some practical relevance.
Snell v HMRC [2006] ALL ER (D) 336
 
The first case I want to look at concerns the tests in...

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