MacKinlay v. Arthur Young McClelland Moores & Co., [1989] S.TC 898, [1989] UKHL TC, [1989] BTC 587 (HL) -- summary under Paragraph 96(1)(a)

Lord Oliver rejected a finding of the Court of Appeal that a firm of accountants could be regarded as a "notionally distinct entity" in order to assess the purpose of expenditures incurred by it in reimbursing the relocation expenses of its partners. "Partners are partners, however numerous; and mere numbers cannot in itself justify an attribution of a 'collective purpose' unjustified in the case of a small partnership."