Patrick v Inland Revenue [2002] EWCA Civ 1649 (25 October 2002)

Patrick v Inland Revenue [2002] EWCA Civ 1649 (25 October 2002)

No important point of principle or practice arises; the General Commissioners' decision was properly open to them based on the material; procedural requirements were complied with; human rights arguments were unfounded.

Citation
[2002] EWCA Civ 1649
Parties
Applicant: Jocelyn Brownlow Patrick; Respondents: Commissioners of Inland Revenue
Jurisdiction
England and Wales
Judgment Date
25 October 2002
Procedural Posture
Civil Appeal / Permission to Appeal From Chancery Division
Outcome
Application dismissed
Legal Topics
Section 20 Notice Compliance, Penalty for Non Compliance, Procedural Fairness, Human Rights (article 6, Article 3, Article 4.2)
Tax Law Civil Procedure Section 20 Notice Compliance Penalty for Non Compliance Procedural Fairness Human Rights (article 6, Article 3, Article 4.2)

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Parties

Jocelyn Brownlow Patrick

Applicant

Commissioners of Inland Revenue

Respondents

Procedural Posture

Civil Appeal / Permission to Appeal From Chancery Division

Legal Issues

  1. 1 Whether the General Commissioners' decision was perverse
  2. 2 Whether the section 20 notice was properly served
  3. 3 Whether the requirements of the notice were reasonable

Ratio Decidendi

No important point of principle or practice arises; the General Commissioners' decision was properly open to them based on the material; procedural requirements were complied with; human rights arguments were unfounded.

Court Disposition

Application dismissed

Orders

  • Permission to appeal refused