Queen’s Bench Division (Crown Office List).

Latham J.

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.

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