LON (88/987)

No. 4832

Decision given 2 May 1990.

Assessment – Alleged underdeclaration of tax – Compounding agreement – Criminal proceedings against appellant and two employees compounded on agreed terms of payment to commissioners – Dispute as to period covered by compounding agreement – Whether all arrears during period covered – Admissibility of extrinsic evidence of terms of agreement.

  The issue was whether the agreement concerning terms of compounding of criminal offences by the appellant company to the commissioners applied to all arrears of tax or only to the sum concerned in the compounded criminal proceedings.

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