Summary
Share loss relief (under ITA 2007, s 131) was denied as the taxpayer was unable to produce satisfactory evidence that the shares (other than the subscriber share) were issued to him.
Background
The appellant entered into a trading business venture with a business partner. The appellant paid £250,000 into a company in February 2008. The venture proved unsuccessful within a few months. Insolvency practitioners were appointed as administrators of the company in February 2009, and it was eventually dissolved in September 2011.
The appellant claimed share loss relief (under ITA 2007, s 131) in his tax return for 2008/09. However, following an enquiry into the return, HM Revenue and Customs (HMRC) issued a closure notice disallowing his claim for the loss relief of £250,000. The appellant appealed.
The key question was whether
