Horton v Young

 CA 1971 47 TC 60 [1972] CH 157 164 [1971] 3 ALL ER 412

A subcontracting bricklayer assessed as self employed claimed travelling from work to site as an expense.  The bricklayers tools were kept at home and his books were written up at home.  In addition, the bricklayer held meetings at his house with contractors to establish fees.  

The travel included daily travel to building sites, picking up other bricklayers and inter-site travel.  The daily travel varied between 5 and 55 miles.  Each project would take no more than three weeks.  The bricklayer claimed the whole expense, the Revenue wanted to only allow the inter-site travel.  It was held that whole expense was allowable as it satisfied the wholly and exclusively rule.