JUDGMENT CANNAN J: Background [1] The appellants (the trustees) are the trustees of a settlement known as the Mrs M Seddon Second Discretionary Settlement which was established on 5 March 1999. The original trust property settled by Mrs Seddon was £1 ordinary shares in Seddon Seedfeeds Limited. At the commencement of the settlement the shares …
JUDGMENT MRS JUSTICE PROUDMAN DBE: The issue [1] This is an appeal from the decision dated 21 April 2011 of the First-Tier Tribunal (Tax Chamber), comprising Mrs Barbara Mosedale and Mr J Stafford. That hearing was an appeal against notices of determination issued to the appellants on 15 October 2009 that a disposal by way …