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R v. O’Kane and Clarke, ex p. Northern Bank Ltd [1996] STC 1249 (QBD)

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 [1997] STC 832; ground (b) left standing

David Goldberg QC and John Walters appeared for the taxpayer

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