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The taxpayer operated a retail clothing business through two companies (S and F) both of which owned trading subsidiaries.
On 31 March 1982 he beneficially owned all the shares in S and F. In October 1983 just before they were floated on the Unlisted Securities Market the F shares were exchanged for further shares in S (known as the new S shares) making F a wholly owned subsidiary of S.
Between the tax years 2000/01 and 2004/05 the taxpayer sold a number of shares and reported the capital gains in his self assessment returns.
HMRC disputed the value of the companies claiming it was too high and after an enquiry issued closure notices amending the returns on the basis that the value of the two companies at 31 March 1982 ...
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