Reference no: EM133801472

Question

We can apportion expenditure. In this case they couldnt as they hadnt established clearly in their contracts which payment were for which parts of the behaviours. They had not said we will give you pay for your super annuation in return for the restrictive covenant and everything else to get rid of you. The contract didnt do that. Everything was lumped in together. Here are all the thing you get and here are the things that are in response to. That Means there wasnt a basis on which to do that apportioning. One of thing with apportioning you have to have a reasonably robust way of doing that apportionment. You rem when we talk about bank case, we can aportion it as you can measure the dining room and then your dining room can be assessed as a certain proportion of you overall house space. That is the good method that inland rev is happy with. When it comes to arrangement like this is subjective. There is No way of determining which payment is related to what part of the contract. The entire deduction was denied. Denied on a procedural ground rather than the outcome here. The outcome still holds but buckley and young wasnt allowed the eduction bec they could established what components were rev. explain this.