28 Oct 2009
FOODSTUFFS (WELLINGTON) CO-OPERATIVE SOCIETY LIMITED V COMMISSIONER OF INLAND REVENUE HC WN CIV 2009-485-1224
- Citation
- openlaw-9be80a7e_2100_496f_9023_64d3a63fb581.pdf
- Court
- High Court
Because the shares were acquired as trading stock for the purpose of disposition and were disposed of (cancelled) at less than market value, s GD 1 applied to treat the disposition as a sale at market value and to deem $2.3 million gross income to the taxpayer; the statute does not require an actual transferee for s GD 1 to operate.