HEADING:
CUP logo with the legend: The right of the University Press to print and sell all manner of books was granted by Henry VIII in Royal Letters Patent of 20 July 1534
CHIEF EXECUTIVE'S OFFICE
CAMBRIDGE UNIVERSITY PRESS
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Chief Executive Geoffrey A. Cass M.A.
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At foot of page:
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GAC/AP

16th December 1976

Dear Mr Marsh,

Thank you for your letter of 3rd December, and for the enclosed Form R68.

I have pleasure in enclosing the completed Form R68 which embodies our claim. This letter, and the form, are being despatched express and recorded delivery.

I enclose the relevant warrants from the Iron Trades Employers Insurance Association Ltd. I also enclose such Corporation Tax receipts as we can readily lay hands on. Where we have been unable to supply a receipt we have noted the dates of payment on the claim form.

I understand that interest on the claimed repayment is paid automatically without further action on our part.

You will note (in connection with my telephone call to you of 10th December), that our claim treats 1974 as the year from which the six years' retrospection is calculated. I do hope we are not going to bog down on a technicality relating to our 1974 Appeal against the additional 1972 assessment. The Inland Revenue has on its files a note of a telephone conversation between the Press's tax adviser, Mr Paul Morris of Binder, Hamlyn, and Mr Mashiter of Cambridge 1 Tax District. During this conversation, Mr Morris informed Mr Mashiter of the University's intention to challenge the liability to Corporation Tax; he further discussed with Mr Mashiter (on my explicit instructions) not only the question of normal 6 years' retrospection but also the possibility of a claim going back much further in time than 6 years - in view of the special nature of the University's case. At the end of the discussion, Mr Mashiter advised Mr Morris that the University should go about the matter by challenging the additional assessment for 1972, and that this would be used as a focal point by the Inland Revenue for consideration of the University's case in general, and in particular of the whole question of retrospection. (The actual phrase used was: "we will look at the previous years as well"). The Appeal Form, dated 8th October 1974 was submitted, on Inland Revenue advice, on this basis, on this understanding.

It would in any case not have been logical or reasonable to suppose in 1974 that the University's appeal could imply anything other than a claim for normal retrospection, or that the 1972 assessment was being appealed against in isolation. The University's situation in 1974 was exactly the same as the case submitted in my letters of 1975. That is to say that the "special nature of the University's case", (to which I referred above) must always have implied a retrospective claim, from the moment that it was raised, even if the telephone conversation had never occurred. The University's submission is timeless. It is not saying that anything different suddenly happened at some point in time, or that the activities of the University Press suddenly changed. The University is saying that the Press's case has always qualified for charitable exemption, although it did not have it.

However, the logical argument is hardly necessary, for the telephone conversation did take place - and the logical argument merely confirms and supports the nature of that telephone conversation. A massive amount of work had been done by the Press and by the University before Mr Morris was authorized to make that telephone conversation, and I hope you will accept (even if your own records do not happen to have the full details of the conversation) that it is quite inconceivable that the call would not have dealt with the matters outlined above (since that was the whole purpose of the call) and inconceivable that we would have submitted an Appeal which chose to challenge only 1972 unless advised to do so.

Yours sincerely,

Geoffrey Cass

H.A. Marsh, Esq.
H.M. Inspector of Taxes
Inland Revenue Claims Branch
Magdalen House
Stanley Precinct
BOOTLE, Lancs L69 9BB

Enclosure (omitted): completed R68 Form

The claimed overpayments of tax listed in the R68 Form are (handwritten) as follows:

For the accounting period to	31/12/1968	£50,000.00
	31/12/1969	£13,077.70
	31/12/1970	£15,000.00
	31/12/1970 AP	£82,447.17
	31/12/1971	£50,000.00
	31/12/1971	£17,500.80
	31/12/1972	£72,000.00

There follows a series of calculations of interest supplements on each overpayment.

[Also photocopied of the reverse of the photocopy of the R68 Form are I.R. payment slips to CUP with reference X36122 (under the name F. H. BROOMAN) for £180,132.29 and £90.53 (both dated 28th February 1977) and £45.67 (dated 21st March 1977).]