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HMRC internal manual

Business Income Manual

Measuring the profits (particular trades): land: trading transactions: land cannot have a dual or indeterminate status

Land cannot have an indeterminate status when it is acquired; Lionel Simmons Properties Ltd v CIR [1980] 53TC461 established that on acquisition it is either stock in trade or it is a capital asset. It cannot be both (see Lord Wilberforce’s comments at pages 491-492).