Inland Revenue CLAIMS BRANCH

Reference X36122/HAM

Date 23 December 1976

CAMBRIDGE UNIVERSITY PRESS

In accordance with Mr Briddon's minute of 9 November, the Chief Executive of the Press was notified on 3 December that it was now agreed that S360(1)(e) exemption was available in respect of the trading profits.

As you will see from his letter of 16 December, Mr Cass is contending that the 6 year time limit for S43 TMA 1970 purposes should run from October 1974, not the present date. At present the accounting periods which are within date are those commencing 1 January 1970, whereas in October 1974 the earliest in date Period was that commencing 19 January 1968. The tax involved for 1968 and 1969 is [XXXXXXXXXXX]*

The district file has been seen and although I did not keep a copy of the notes of telephone conversation between the Inspector and the Tax Adviser in October 1974, I recall that they were brief and related solely to the estimated assessment for 1972 itself. There was no mention of any discussion regarding retrospection - whether it be back to 1968 or even earlier - but the comments in Mr Cass's letter have a ring of authenticity about them and they're certainly quite logical.

In the circumstances is it agreed that the claim should be admitted from January 1968?

My files X36122 and CR61007 are attached.

H.A.M.

* Amount redacted by the Inland Revenue in 2009 under FoI exemption (s)41. Closed until 2019. Click for the collated Redaction puzzle-file, with scans.