Notices requiring a third party to produce documents, issued by the Inland Revenue during tax investigations. s.20(3) TMA 1970.The notices were quashed on the grounds (a) that they required the production of conjectural as distinct from actual documents and for that reason were outside the scope of s.20(3) TMA 1970; and (b) that they were oppressive and unfair in that they required production of material which would be largely or wholly ignored by the Revenue.N.B. Ground (a) above disapproved by the Court of Appeal in R v. IRC, ex p. Ulster Bank Ltd  STC 832; ground (b) left standingDavid Goldberg KC and John Walters appeared for the taxpayer
R v. O’Kane and Clarke, ex p. Northern Bank Ltd  STC 1249 (QBD)
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19 Jul 2023
GITC is sad to report the death of our Head of Chambers, Mr Milton Grundy who passed away at the weekend.
Gray’s Inn Tax Chambers is deeply saddened by the passing of our founding member and Head of Chambers, Mr Milton Grundy
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