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Digging for riches

05 July 2011 / Anne Redston
Issue: 4311 / Categories: Comment & Analysis
ANNE REDSTON kicks off a series of occasional articles on the principles of ancient tax cases

Once upon a time I was history student analysing medieval manuscripts and researching revolutions. Although Bede and Lenin are no longer my bedtime reading I still believe that the past informs the present – and no more so than in tax.

The very first case reported in Tax Cases is Re Addie & Sons (1875) 1 TC 1 (Addie). Although over a century old it remains the leading authority on the non-deductibility of depreciation. In CRC v William Grant; Small v Mars Ltd [2007] STC 680 Addie was cited at every stage as the case progressed from the Special Commissioners to the House of Lords.

Addie & Sons was a mining business that incurred substantial expenditure digging pits setting up the related machinery (such as winding and pumping engines) and constructing pithead buildings.

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