Chancery Division.

[The appeal against this decision is reported at [1999] BTC 310.]

Neuberger J.

Judgment delivered 10 February 1998.

Capital gains tax – Agreement between taxpayer and Revenue – Assessment of over £3m – Amended assessment of nil issued in error – Taxpayer did not acknowledge amended assessment – Second amended assessment restored original assessment – Whether first amended assessment became final after 30 days – Whether first amended assessment and taxpayer’s failure to respond constituted agreement – Whether agreement had to amount to a legal contract – Taxes Management Act 1970, s. 54.

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