References: (1985) 58 TC 592,  UKHL 3,  2 All ER 375,  AC 645
Coram: Lord Fraser of Tullybelton, Lord Keith of Kinkel, Lord Bridge of Harwich, Lord Brightman, Lord Templeman
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.
This case is cited by:
- Cited – Langham (HM Inspector of Taxes) v Veltema CA (Bailii,  EWCA Civ 193, Times 11-Mar-04,  STC 544)
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 . .