000			01567cab a2200265 4500
001			ABS59117
008			090401t1998 xxu||||| |||| 00| 0 eng d
035			_a(Sirsi) u87350
041			_aeng
245			_aWatton (HM Inspector of Taxes) v Tippett
260			_c1998
350			_a0
490			_aTax Cases _v[1998] TC 491-509(19)
520			_aCA 22 May 1997. T purchased property and spent money on improving it. Later he partitioned the property into two, and in 1989 sold part at a profit. T successfully appealed against an assessment to capital gains tax in respect of that part disposal, claiming roll-over relief under Capital Gains Tax Act 1979 s 115, on the basis that the gains arising on that part disposal should be set off against the residue of expenditure attributable to the retained part of the premises. The Crown successfully appealed on the grounds that roll-over relief was not available, as a part disposal of an asset is to be treated as a disposal of the asset and, it could not be said that any quantifiable part of those proceeds had been `applied` in the acquisiton of the retained part. T`s appeal to the CA was dismissed on the basis that there must be an acquisition of assets other than the assets disposed of.
650			_aCAMPBELL CONNELLY V BARNETT
650			_aCAPITAL GAINS TAX ACT 1979 S115
650			_aENHANCEMENT EXPENDITURE
650			_aNEW ASSETS
650			_aOLD ASSETS
650			_aPART DISPOSAL
650			_aROLL OVER RELIEF
690			_aTAXATION-CASE LAW
942			_n0
948			_c13/07/1998
999			_c55095 _d55095