Chancery Division.

Hoffmann J.

Judgment delivered 12 June 1992.

Corporation tax – Appeal commissioners’ powers – Losses set off against estimated assessments which were not appealed – Estimated assessments found to be excessive after they had become final – Appeal against assessments for later years – Whether commissioners entitled to find that taxpayer was ‘overcharged’ on earlier assessments releasing losses to be utilised against liability in later years – Taxes Management Act 1970, sec. 50(6).

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