Lloyd's Law Reports

Professor Robert Merkin KC; Dr Johanna Hjalmarsson

Document

SIMPSON v. JOHN REYNOLDS & CO. (INSURANCE) LTD.

[1975] 1 Lloyd's Rep. 512

COURT OF APPEAL

Before Lord Justice Russell,Lord Justice Stamp andMr. Justice Walton

Income tax - Profits arising or accruing from trade - Client terminating trading connection with taxpayer - Client making voluntary payment to taxpayer in recognition of past services - Services provided by way of trade - Whether payment chargeable to tax as a trading receipt - Income Tax Act, 1952, ss. 122 123 (Sched. D., Case I).

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