“…ns-Lombe sitting in the High Court, on appeal from a special commissioner (Julian Ghosh QC), in Thorpe v Revenue and CustomsCommissioners [2009] EWHC 611 (Ch), [2009] STC 2107 (“Thorpe”).…”
“…idered Draconian, but he could find nothing in the relevant provisions of ICTA 1988 to indicate that this was not the result prescribed by the legislation: see [2009] STC 2107 at 2120a. It was therefore unnecessary for him to consider the alternative charge to tax under section 600, it being common ground that such a charge could not…”