Revenue Precedents

The due date for the balance of tax where a taxpayer completes an incomplete return is the same as that for the tax charged in the original assessment. However, if the taxpayer is relying on the 90% rule, the amendment may mean that the Preliminary Tax payment is made inadequate by the amendment in which case the due date reverts to the Preliminary Tax due date. IT932023

The capital allowances figure in a return of income is a material fact for the purposes of determining whether a full and true disclosure of all the material facts was made. IT952559

The surcharge under section 1084 is ignored in considering if Preliminary Tax payment is adequate. IT902018