[2003] EWHC 781 (Ch).

Chancery Division.

Lloyd J.

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).

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