Chancery Division.

Rattee J.

Judgment delivered 7 February 1996.

Income tax – Schedule E – Additional emoluments – Taxpayer director of two companies – Payments made by one company not received by other – Inference that taxpayer had received payments – Taxpayer alleging assessment excessive – Whether onus was on taxpayer to establish assessment was excessive – Taxes Management Act 1970, s. 50(6).

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