1. Efisio Puddu appeals against an assessment to capital gains tax laid on him on 20 July 1989 for the year 1988/89 in the estimated sum of £100,000. Mr Puddu is not resident in the UK. He did not appear before me nor was he represented on the appeal. His accountants, Newby Castleman, informed the clerk to the Special Commissioners that this would be the case in a letter dated 2 June 1995.