[2003] EWHC 113 (Admin).

Queen’s Bench Division (Administrative Court).

Lightman J.

Judgment delivered 5 February 2003.

Income tax – Capital gains tax – Tax fraud – Restraint order – Receivership – Confiscation order – Defendant convicted of tax fraud – Confiscation order made – Receiver appointed under restraint order realised assets to satisfy confiscation order – Whether receiver liable for income or capital gains tax on realisations – Whether defendant’s tax liability expense of receivership – Criminal Justice Act 1988, s. 77, 81, 82, 88 – Taxes Management Act 1970, s. 75, 77.

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