Key words: Tax avoidance – Income Tax – Discounts – Gilt strips –
Computation of loss – Scheme designed to create excess of amount paid for
the strip over the amount payable on transfer – Excess represented by
“premium” for grant by taxpayer of call option – Whether option price to be
added back in determining amount payable on the taxpayer’s transfer – Yes
– Appeal dismissed – Para 14A Sch 13 FA 1996.