Queen’s Bench Division (Crown Office List).

Judgment delivered 23 July 1986.

Corporation tax – Assessment – Special Commissioner giving leave to raise corporation tax assessment out of time – Discretion – Judicial review of decision – Whether Commissioner acted unreasonably and irrationally – Whether evidence to show probability that taxpayer failed to make a return – Whether evidence that Crown might have lost tax – Taxes Management Act 1970, sec. 41.

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