Court of Appeal (Civil Division).

Neill, Waite and Saville L JJ.

Judgment delivered 13 January 1995.

Value added tax – Registration – Taxpayer failed to register – Tax assessed in respect of 12-year period when he should have been registered – Whether assessment properly made – Value Added Tax Act 1983, Sch. 7, para. 4; sixth VAT directive (Directive 77/388) of 17 May 1977 (OJ 1977 L145/1), art. 22(4), (8); Value Added Tax (General) Regulations 1975 (SI 1975/2204), reg. 51; Value Added Tax (General) (Amendment) Regulations 1976 (SI 1976/1234); Value Added Tax (General) Regulations 1985 (SI 1985/886), reg. 58(1)(c).

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