Where an appeal against an assessment to tax had been settled by agreement, any dispute as to the scope of that agreement was to be viewed objectively, having regard to the surrounding circumstances, including all the material known to be in the Inspector’s possession.
Lord Fraser of Tullybelton, Lord Keith of Kinkel, Lord Bridge of Harwich, Lord Brightman, Lord Templeman
(1985) 58 TC 592,  UKHL 3,  2 All ER 375,  AC 645
England and Wales
Cited – Langham (HM Inspector of Taxes) v Veltema CA 26-Feb-2004
The tax inspector had sought to re-open a tax assessment outside the time limit provided. He had discovered that a house had been given to the tax payer by his employers. The taxpayer said this had been discoverable from his self-assessment tax . .
Lists of cited by and citing cases may be incomplete.
Updated: 30 June 2022; Ref: scu.225367