Most case law refers to the officer as the ‘hypothetical officer’. However, the statute gives no clue as to who this officer is and what skills (if any) should be attributed to him.

The question was not generally relevant in the earlier cases which made reference variously to:

‘the general knowledge and skill that might reasonably be attributed to an officer’;

‘equipped with a reasonable knowledge of tax law’;

‘the general knowledge and skill that might reasonably be attributed to him’; and

‘an ordinary competent inspector’.

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