Schuldenfrei v Hilton (Inspector of Taxes)
| Jurisdiction | England & Wales |
| Judgment Date | 10 February 1998 |
| Date | 10 February 1998 |
| Court | Chancery Division |
Chancery Division
Before Mr Justice Neuberger
Schuldenfrei
and
Hilton (Inspector of Taxes)
Capital gains tax - silent acquience to erroneous notice of assessment- agreement not created
Acquiescence to error does not create an agreement
An amended notice of assessment reducing a capital gains tax assessment to nil issued by a tax inspector in error and deliberately not responded to by the taxpayer did not constitute an agreement for the purposes of section 54 of the Taxes Management Act 1970.
Mr Justice Neuberger so held in the Chancery Division dismissing an appeal by the taxpayer, Mr Henry Schuldenfrei, from a determination by special commissioners that his appeal against the original assessment on chargeable gains of £3.4 million for 1987-88 was not to...
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6 cases
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Harrahill v Kane
...ACT 1997 S933(3)(D) R v INSPECTOR OF TAXES EX-PARTE BASS HOLDINGS LTD 1993 STC 122 SCHUDDENFREI v HILTON (INSPECTOR OF TAXES) 1998 STC 404 WAUGH v HB CLIFFORD & SONS LTD 1982 1 AER 1095 PRACTICE AND PROCEDURE Summary judgment Value added tax - Assessment - Appeals Commissioner - Precepts is......
- Schuldenfrei v Hilton (Inspector of Taxes)
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Commissioners of Customs and Excise v DFS Furniture Company Ltd (No 2)
...of section 85 or at common law. That is fatal to DFS's case. I agree with the observations of Jonathan Parker J in Schuldenfrei v. Hilton [1999] STC 821 at 831 (a decision on similarly worded provisions in section 54 of the Taxes Management Act 1970) that "….the notion of parties having "co......
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Littlewoods Retail Ltd and Others v The Commissioners for HM Revenue & Customs
... ... the goods or the provision of services, including all expenses and taxes except the value added tax itself; …" ... [1988] STC 392 at 408j-409c (Knox J), Barnett v Brabyn (Inspector of Taxes) [1996] STC 716 at 723c-j (Lightman J), MacNiven v ... Swift referred me to the decision of the Court of Appeal in Schuldenfrei v Hilton [1999] STC 821 ... The issue in that case was whether the ... ...
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