Entitlement to losses from dissolved partnership

Douglas Shanks LLP carried on the profession of accountancy. The members of the partnership were the taxpayer and Celestial Accounting a dormant company. The taxpayer ceased to practise with the firm in June 2008 since when he practised as a partner in other firms. He included partnership pages for Douglas Shanks LLP in his 2008-09 return. In those he claimed losses of £221 667 and carry-forward losses of £235 298. The return also contained self-employment profits from his work for another practice. 

The 2009-10 and 2010-11 returns showed self-employment profits from other practices but no partnership pages were completed. Instead the taxpayer used the ‘white space’ to explain he had always traded as an accountant and that he had moved from Douglas Shanks LLP to a new partnership. But he stated that his income was ‘treated as one profession throughout the time in the returns and should be treated...