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INCOME TAX –partnerships engaging in sale and leaseback of films and partners claiming losses under film acquisition relief provisions ss130-140 ITTOIA – whether trading - held no - appeal dismissed – if trading, whether business carried on on a commercial basis – amount of acquisition expenditure incurred in respect of original master version of The Queen – whether partnership loss rules s118ZE ICTA restrict use of any loss – whether Proteus’s relevant period less than 12 months s138 of ITTOIA – whether expenditure of a revenue nature JUDICIAL REVIEW – whether claimants had legitimate expectation derived from HMRC’s Business Income Manual – whether claimants had legitimate expectation derived from HMRC’s settled practice – whether HMRC acted with conspicuous unfairness.