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

鈥淭he 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. They are,to my mind, deceptive words in the sense that when examined they are found to come to nearly nothing at all.鈥�

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

鈥淚t 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].鈥�