Cape Brandy Syndicate v CIR

CA 1921 12 TC 358 [1921] 2 KB 403

Members of a wine syndicate joined in a separate syndicate to purchase brandy from South Africa.  Some was shipped to the East with the remainder being sent to London to be blended with French Brandy, re-casked and sold at a profit.  The taxpayer tried to argue that the transaction was of a capital nature from the sale of an investment.  It was held that a trade or business was carried on and was assessable as a trading profit.