TSEM7020 - Tax Cases: CIR v Plummer 54 TC 1
Summary
In a tax avoidance scheme an individual received a lump sum and
in exchange made covenanted payments. He claimed a deduction for
the payments in computing his total income.
Decision
The covenanted payments were income payments and the
Settlements legislation did not apply to the arrangement. This is
because the individual had received full consideration and there
was no element of bounty.
TSEM references
TSEM4105
