Readers' forum - Twin peaks

In 1995 my client a surgeon with a private practice formed a partnership with his wife who was neither a surgeon nor a medical practitioner of any sort; a fact that I brought to the Inland Revenue's attention at the time. (See the Readers' forum query 'Peak practice' Taxation 6 April 1995 page 20.)
After some initial hesitation the Revenue accepted the existence of the partnership and I concluded in a letter to my client in November 1995 that '… there can be no doubt at the validity of this decision since a full disclosure of all the facts has been made'.
Tax returns have been routinely submitted since then with profits split 60/40 in favour of the husband.
The Tax Bulletin 64 and Jones v Garnett brought the matter back into my mind. Sadly I no longer have the copies of...