*R (on the application of Silva and another) v Revenue and Customs Commissioners

Income tax – Loss relief. The Revenue and Customs Commissioners rejected the taxpayers' claims to set off trading losses in respect of certain partnerships so as to reduce their payments in respect of tax due, as the partnerships had entered into a settlement agreement. The taxpayers sought judicial review. The Upper Tribunal (Tax and Chancery Chamber), in dismissing the application, held that as a result of the restatement of the partnership losses under the settlement agreement, the taxpayers had lost the right to carry back to earlier years the higher pre-amendment losses which had been claimed.