Chancery Division.

Jonathan Parker J.

Judgment delivered 24 January 1992.

Capital gains tax – Deductible expenditure – Claim to deduct expenditure unsupported by evidence – Whether general commissioners justified in rejecting claim.

Default interest – Estimated assessment – Further assessment raised when inspector discovered true position – Taxpayer had not disclosed amount of gain until discovered by inspector – Whether taxpayer guilty of wilful default or neglect – Whether general commissioners justified in issuing certificate for default interest – Taxes Management Act 1970, sec. 70(3), 88(1).

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