“…sier to meet). Rather, the trade must be carried on in a way reflective of someone “seriously interested in profit” per Wannell v Rothwell (Inspector of Taxes) [1996] STC 450. A proper consideration of this test would have led to the conclusion that there was a significant risk that it would not be fulfilled, as any reasonably compe…”
“…The test of commerciality now contained in section 66 has been considered in previous cases. In Wannell v Rothwell [1996] STC 450 Robert Walker J said:…”