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The taxpayer company was incorporated in December 2002 to provide consultancy and advisory services in relation to construction estimating project management quantity surveying and housing management services.
The directors Mr and Mrs J bought land with planning permission to build a single storey dwelling in Florida. It was decided the company would manage the project.
The directors would as clients of the company pay for the use of their own time and expertise based on cost plus 5%.
The property was finished in April 2006 although by May 2006 only 60% of the construction cost had been demanded from the company.
Mr J subscribed for 86 000 £1 shares in the company in December 2004; in January 2005 a claim for an enterprise investment scheme (EIS) was made.
HMRC accepted the claim but withdrew acceptance in December 2006 on the basis that...
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