Smiths Potato Estates Ltd v Bolland

HL 1948 30 TC 267 [1948] AC 508 [1948] 2 ALL ER 367

Following a successful tax appeal the taxpayer claimed the cost of appealing which included legal and accountancy costs.  The claim was rejected as it was not incurred wholly and exclusively for the purposes of the trade.  The costs had been incurred by the taxpayer in their capacity as a taxpayer and not in the capacity of the trade.