Lloyd's Law Reports

Professor Robert Merkin KC; Dr Johanna Hjalmarsson

Document

SIMPSON (INSPECTOR OF TAXES) v. JOHN REYNOLDS & CO. (INSURANCES) LTD.

[1974] 2 Lloyd's Rep. 334

CHANCERY DIVISION

Before Sir John Pennycuick, V.-C.

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 (Sch. D., Case I).

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