Agreement with Revenue
Appeal settled by, accountant's authority
Capital gains tax assessment
Construction precluding Revenue from raising enquiries and serving notices
Duties of care and management
Extinguishment of tax liability
Further assessments precluded by agreement
Pecuniary settlement, prosecution by Crown Prosecution Service
Case Law –
R v. Werner & Anor. [1998] BTC 202
Rectification
Resile
Abuse of power or breach of Convention rights
Case Law –
Al Fayed & Ors v IR Commrs. [2006] BTC 70
Unfairness
Case Law –
R (on the application of Bamber) v Revenue and Customs Commissioners. [2006] BTC 146
;
R (on the application of Bamber) v Revenue and Customs Commissioners. [2007] BTC 577
Ultra vires action