Atkins, The Executors of v HMRCC [2011] UKFTT 468 (TC)
Wills & Trusts Law Reports | December 2011 #115David Atkins (the deceased) had been a Lloyd’s ‘name’ and, during the final year prior to his death, he had made a loss which was disclosed in his tax return. However, there existed a special reserve account for the purpose of meeting anticipated claims and it was the accepted practice that the balance was deductible from what would otherwise have been profits of particular years or subjected to tax if and when subsequently released. While ordinarily income accruing to the executors would be taxed at 20%, legislation provided for any relief to be added back to the ...