Mr plimmer wanted to take over a company . In order to take over the company he need to buy all the hares in that company. With that company, the company has lots of ordinary shares, which you need to take over company and had preferred shares. Plimer couldn't just buy ordinary shares but also had to buy the preference shares. He only wanted the ord share not the preferred share. He had to buy all of them. He got shares and owns the company. He sold the preference shares. Inland reve tries to tax him on the basis he had the purpose of disposing of them. He was able to demonstrate was that he didnt have a purpose. His purpose was to take over the company. That was his purpose of buying those shares. He had intention of disposing them as he didnt want them. He was happy to say that was his intention. But wasnt his purpose. The purpose of buying preferred shares was to get on hand with ordinary shares and take over the company. His intention was to get rid of them as he don't want them. With that example, purpose and intention was different. The purpose relates more the facts associated with object you selling - this case is particular. It about him acquiring things he didn't want. It is unusual in that perspective. Always look to the facts of the cas