[2002] EWCA Civ 1879, 20 December 2002. In 1987, the respondent (J) and his brother contracted to sell land that they held on trust for themselves and J's wife as tenants in common. In 1988 J transferred part of their beneficial interests in the land to the trustees of two overseas settlements. An issue arose as to the capital gains tax (CGT) payable by J in respect of the sale. The Inland Revenue (IR) assessed J to CGT on the gains referable to the proceeds of the sale based upon the Capital Gains Tax Act 1979 s27(1). The High Court allowed J's appeal against the assessment on the grounds that the matters deemed under s27(1) of the 1979 Act were confined to the time of the disposal and not to the parties to it or the subject matter of it. IR appealed. CA held that IR was correct in its initial assessment. S27(1) of the 1979 Act applied to disposals under the 1987 contract which effected the completion of the sale. In accordance with s46(1) J was one of the vendors for CGT purposes. Appeal allowed. View judgment at www.courtservice.gov.uk