1. Private Clients
1.1. Claim for negligible value and valuation of shares
The First Tier Tribunal cases of Messrs Barker, Harper &
Wickes v Revenue & Customs (TC01487) concerned the valuation of
shares and claim of negligible value.
The taxpayers won their appeals and the very long published
decision provides an interesting outline of the points at issue and
background detail. The appeals were joined because the issues in
each of the three cases were the same, but the claims and the
appeals were distinct.
The taxpayers had acquired shares in a company called Diligenti
Limited on 19 December 2000 and had made a claim under TCGA 1992
s24(2) on the basis that their holdings had become of negligible
value by 5 April 2001. Each holding was of 11,000 ordinary shares
of one penny, which were subscribed at par with a premium of
£303.0203 per share, so that each taxpayer paid a total of
£3,333,333 for his shares.
