Queen’s Bench Division. Crown Office List.

Judgment delivered 17 January 1986.

Income tax – Judicial review – Artificial transactions in land – Application for leave to apply for judicial review – Directors assessed to tax personally on company’s gain – Whether arguable that assessment irrational – Whether arguable that inspector acted improperly or in abuse of Revenue powers in making the assessment – Income and Corporation Taxes Act 1979, sec. 48(8) para. 8.

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