[2009] CSIH 6.

Court of Session (Inner House, Extra Division).

Lord Osborne, Lord Wheatley and Lord Brodie.

Judgment delivered 10 February 2009.

Income tax – Tax return – Assessment – Appeal – Taxpayer submitting tax return – HMRC commencing inquiry – HMRC amending return to make good loss of tax attributable to taxpayer’s negligent conduct – General Commissioners dismissing taxpayer’s appeal – Whether commissioners misconstruing statutory duty – Whether decision reasonable – Taxpayer’s appeal dismissed – Taxes Management Act 1970, s. 28A, 36.

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