InS Gray v HMRC[2016] UKFTT 397 (6 June 2016) the FTT found that the taxpayer had carried out the trade of promoting his wife as a concert pianist but that he had not carried out this trade commercially.
Mr Gray ran a sole practice as a tax attorney and counsellor at law. His wife was a concert pianist and he had become her promoter.
HMRC had opened an enquiry into his return and had found that the losses claimed by Mr Gray were invalid as he had not carried out the trade of promoter; or alternatively he had not carried out this trade on a commercial basis or with a view to profits (ITA 2007 s 66).
The FTT observed that the question of motivation must have some relevance to the ‘trade’ issue as well as that...
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InS Gray v HMRC[2016] UKFTT 397 (6 June 2016) the FTT found that the taxpayer had carried out the trade of promoting his wife as a concert pianist but that he had not carried out this trade commercially.
Mr Gray ran a sole practice as a tax attorney and counsellor at law. His wife was a concert pianist and he had become her promoter.
HMRC had opened an enquiry into his return and had found that the losses claimed by Mr Gray were invalid as he had not carried out the trade of promoter; or alternatively he had not carried out this trade on a commercial basis or with a view to profits (ITA 2007 s 66).
The FTT observed that the question of motivation must have some relevance to the ‘trade’ issue as well as that...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")