Court of Appeal (Civil Division).

Lord Donaldson MR, Nourse and Bingham L JJ.

Judgment delivered 23 March 1990.

Income tax – Notice requiring delivery of document by solicitor to tax inspector for purpose of investigation into his affairs – Documents demanded included material concerning subject matter of assessments under appeal and material relating to clients – Whether power to issue notice in relation to documents relevant to pending appeal – Whether delivery of documents relating to clients would breach duty of confidentiality – Taxes Management Act 1970, sec. 20(2).

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