Grays Timber Products Ltd v Revenue and Customs Commissioners
Supreme Court
“In assessing whether employment-related securities had been disposed of for a price which exceeded their market value, so as to occasion a charge to income tax, it was necessary to postulate a notional sale between a hypothetical vendor and purchaser, with the personal characteristics of the actual vendor, such as his right under a subscription agreement to a disproportionately large part of the consideration paid, being ignored.”
The Times, 4th February 2010
Source: www.timesonline.co.uk