»Ê¹ÚÌåÓýapp

Throughout the case law on the general rule for employees� expenses the courts have emphasised its restrictive nature. For example, in Lomax v Newton (34TC558) Vaisey J commented:

“»Ê¹ÚÌåÓýapp words are indeed stringent and exacting; compliance with each and every one of them is obligatory if the benefit of the rule is to be claimed successfully. »Ê¹ÚÌåÓýappy are,to my mind, deceptive words in the sense that when examined they are found to come to nearly nothing at all.â€�

Again, in McKie v Warner (40TC65), Plowman J commented:

“It has been pointed out many times, and it is unnecessary for me to refer to any of the occasions because it is notorious, that it is very difficult for a taxpayer under Schedule E [employment income] to bring his expenses within the [section].�