Pepper v. Hart

Hart and nine other teachers (plaintiffs) at Malvern College were allowed to send their own children to the school for only 20% of the fee charged to other students, a fringe benefit both sides agreed was taxable as income; the dispute was over how to measure that benefit, with the parents arguing it should be the school's minimal marginal cost of an otherwise-empty seat and the tax collector (defendant) arguing for the average cost per student. A tax commission ruled for the parents, but the High Court and Court of Appeal reversed, and the parents appealed to the House of Lords.