The respondents owned the Rotunda Hospital and certain attached property known as the Rotunda Rooms and Vaults, from the letting of which, provided with light and heat and the necessary furniture, they derived the revenue which the appellant sought to assess under Schedule D of the Income Tax Acts. The respondents claimed that these profits were included in the assessment under Schedule A, and were therefore exempt from taxation under Schedule D. Held that the respondents carried on ‘an adventure or concern in the nature of trade’ which was assessable under Schedule D.
Grove v. Young Men’s Christian Association, 4 Tax Cas. 613; Religious Tract and Book Society of Scotland v. Forbes, 33 S.L.R. 289, 23 R. 390, 3 Tax Cas. 415; and Carlisle and Silloth Golf Club v. Smith, 1913, 2 K.B. 75, approved and followed.
Maugham v. Free Church of Scotland, 30 S.L.R. 666, 3 Tax Cas. 297, distinguished.
Lord Chancellor (Birkenhead), Lords Finlay, Cave, Atkinson, and Shaw
[1920] UKHL TC – 7 – 517, [1920] UKHL 633, 58 SLR 633, [1921] 1 AC 1
Bailii, Bailii
England and Wales
Income Tax
Updated: 29 December 2021; Ref: scu.631524