Rowland v Boyle (HM Inspector of Taxes).  BTC 359
 EWHC 781 (Ch).
Judgment delivered 11 April 2003.
Income tax – Assessment – Interest relief – Time limits – Fraudulent or negligent conduct – Property purchased in name of company owned and controlled by taxpayer – Taxpayer claimed income relief on basis that company acted as nominee in borrowing money on which interest charged – Revenue raised assessments out of time to disallow interest relief – Whether taxpayer knew he was not entitled to relief claimed – Whether loss of tax attributable to fraudulent or negligent conduct of taxpayer – Taxes Management Act 1970, s. 34(1), 36(1).