The issues in this case was:
- Whether the price of purchase of right to dividends were deductible.
- Whether the purchase and sale of right to dividends was trading transaction in course of Appellant’s trade.
- Whether the purchase price expenditure incurred wholly and exclusively for purposes of the trade.
- Whether HMRC were permitted to argue point in relation to section 730 ICTA that was not raised in closure notice and which they stated they were not pursuing
- Whether the price of sale of right to dividends should be disregarded for the purposes of calculating Appellant’s trading profits under section 730(3) ICTA