This case concerned corporation tax and a capital gain realised on the sale of a property. The issue was whether a payment made by the company to a director and former shareholder, who was a controlling party, was deductible for corporation tax purposes. The Tribunal considered the company’s jurisdiction to make a claim in respect of a loan relationship deficit where no such claim had been made before the issue of a closure notice or the expiry of the two-year time limit. It also considered whether the payment constituted a distribution rather than a deductible expense.