“…ity would be regarded as trading, giving proper weight also to the absence of any real speculation and the presence of a tax avoidance motive (see Iswera v IRC [1965] 1 WLR 663). The judge also wrongly concluded that a reasonably competent tax silk could have taken comfort from an HMRC Manual which was not in existence until 2006.…”
“…He did, however, accept as good law what Lord Reid had said in Iswera v IRC [1965] 1 WLR 663 where the taxpayer had acquired 2 acres of land in order to live near to her daughter’s school and had disposed of the excess over what she needed in order to …”