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07 February 2011
Issue: 4291 / Categories: Tax cases , Income Tax
Paul Mellor (TC906)

The taxpayer a self employed electrician worked on various sites. He travelled to the locations by car and claimed motor expenses for the journeys.

Citing the decision in Horton v Young 47 TC 60 he claimed his home was also his work base so the travel was wholly and exclusively for the purpose of his trade.

He said he had no other office all his business records were kept in his home all correspondence  was sent to his home address and he kept some small tools and equipment there when not using them.

HMRC disallowed his claim saying that although the taxpayer might do some work at home it was not where he carried out his trade as an electrician. His travelling costs were not allowable because they were not wholly and exclusively for the purpose of...

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