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The taxpayer who was self-employed claimed loss relief of £100 000 for the tax year ending 2007 under TA 1988 s 380 in respect of the promotion of three classical music concerts that failed to run.
He argued he had promoted the concert in a ‘personal capacity’ and was thus entitled to the loss relief. HMRC refused the loss claim saying West Yorkshire Live Events Ltd (WYLEL) a company of which the appellant had also been a director was the promoter.
The appellant asserted he personally suffered a £100 000 loss from the failed business venture which was made up of a loan of £85 000 to fund a performer’s fees and £15 000 in miscellaneous expenses.
Although HMRC accepted there was a loss from the cancelled concerts they said the evidence pointed...
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