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MALCOLM GUNN FTII, TEP examines the 'wholly and exclusively' rule in the context of Schedule D.
THESE ARE THE thoughts of Chairman Gunn on the 'wholly and exclusively' rule applicable to Schedule D, Cases I and II. Already I can hear the shouts in response: 'He's finally flipped! We know this old stuff better than he does. We have analysed it, agonised over it and argued it down countless years and there's nothing he can tell us about it that we don't already know!'
MALCOLM GUNN FTII TEP examines the 'wholly and exclusively' rule in the context of Schedule D.
THESE ARE THE thoughts of Chairman Gunn on the 'wholly and exclusively' rule applicable to Schedule D Cases I and II. Already I can hear the shouts in response: 'He's finally flipped! We know this old stuff better than he does. We have analysed it agonised over it and argued it down countless years and there's nothing he can tell us about it that we don't already know!'
All that may well be true especially the 'flipped' remark but all the same there are many misconceptions about the rule along with many inconsistencies in the way it has come to be interpreted. It is one of the many foundation stones of our tax system and yet it is full of problem areas and questions without complete answers.
With...
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