R v Inland Revenue Commissioners, ex parte Barker & Anor.  BTC 290
Queen’s Bench Division (Crown Office List).
Judgment delivered 22 June 1994.
Income tax – Interest on tax due – Assessment in agreed amount – Subsequently taxpayers ceased trading and assessment amended in accordance with closing provisions – Actual receipts in last year of trading exceeded original assessment – Whether interest payable from date applicable to original assessment when the final amount could not have been known or assessed – Whether date from which interest ran could be the subject of judicial review proceedings – Taxes Management Act 1970, s. 54, 86.