IRC v. Garvin, [1981] 1 WLR 793 (HL)

In obiter dicta, Lord Russell of Killowen "venture[d] to doubt the ability of the Crown ... having levied a tax on the basis that the transaction...

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It was stated, obiter, that "I can see a powerful argument being mounted to the effect that, if a receipt falls to be treated as income and taxed...

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