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S Murray-Hession v HMRC

In S Murray-Hession v HMRC [2016] UKFTT 612 (2 September 2016) the FTT found that the appellant had subscribed for shares so that share loss relief under TCGA 1992 s 16 was available.

The appellant claimed that he was entitled to loss relief in relation to his investment in a company called Geezer as the shares had become worthless when the company had entered into administration. HMRC contended that he had not subscribed for the relevant shares but that the share capital of Geezer had been subdivided. This allowed Mr Gray then its sole shareholder to transfer 225 shares to the appellant for nil consideration. The appellant must therefore have lent the £270 000 he had invested in Geezer.

The FTT found that the appellant had an agreement with Mr Gray that he would invest £270 000 by way of subscription for shares. This explained why...

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