By an unregistered deed the taxpayer purported to transfer a farm that previously had been acquired by him from his parents back to his parents for a nominal consideration; and 35 days later received the farm back from his parents for a nominal consideration pursuant to a further unregistered deed.
This was found to be a scheme under which the taxpayer appeared to be disposing of the farm to crystallize a capital loss while, in the non-arm's length circumstances of the relationship between him and his parents, he retained the beneficial ownership of the farm.