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Gunson v Commissioner of Inland Revenue - [1987] 1 NZLR 541

$30.00

High Court Wellington
6 July; 14 August 1987
Gallen J
Income tax — Deductions — Offsetting losses from special activity — Taxpayer claimed as a deduction from his principal source of income $21,447 being the loss he sustained from his share of a horticultural partnership — Commissioner limited taxpayer's deduction under s 188A to $10,000 — Meaning of "loss" under s 104 and s 188A — Whether the $10,000 limitation in s 188A refers to the total loss on the activity or to each item making up the loss — Whether interest should be included as part of the loss under s 188A or allowed as a separate deduction — Income Tax Act 1976, ss 104, 106 and 188A(7)(a).

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