Transactions that are equivocal may also be dual motive
transactions. A dual motive transaction is a transaction entered
into with two objects.
An example would be an acquisition of land both to provide
accommodation for an existing trade and for eventual development
and resale at profit. It would be for the Commissioners to decide
as a question of fact in such circumstances whether one of those
motives was a trading motive and, if so, to what extent it coloured
the whole transaction as being, in essence, a trading transaction -
see Nourse LJ's comments, for example, in Kirkham v Williams [1991]
64TC253.
