Inland Revenue Commissioners v Wilkinson.  BTC 297
Court of Appeal (Civil Division).
Neill, Scott and Steyn L JJ.
Judgment delivered 14 April 1992.
Income tax or capital gains tax – Three estimated assessments for each of two years made on taxpayer on different bases – Notice of assessment sent to taxpayer with covering letter alleged to suggest that assessments in respect of the same receipts were cumulative – No appeal against assessments by taxpayer – Writ issued claiming summary judgment for total amount of all assessments – Statement of claim later amended pursuing only one assessment for each year – Whether taxpayer had an arguable defence to the action – Rules of the Supreme Court, O. 14.