City of London Contract Corp., Ltd. v. Styles (1887), 2 TC 239 (C.A.) -- summary under Goodwill, Trademarks and Customer Lists

The taxpayer was incorporated to purchase as a going concern a business of contracting for public works. The purchased business consisted entirely of partially executed or wholly unexecuted contracts and related rights. It was held that the purchase price paid by the taxpayer was capital which the taxpayer had paid to embark on the business and accordingly was a capital expenditure.