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The taxpayer practised as a solicitor in the field of asylum and immigration law. She was registered for VAT.
She owed VAT to HMRC and because she did not make the payment the department applied to have a bankruptcy order made against her.
The taxpayer unsuccessfully applied to the chief registrar to have the order annulled on the grounds that it ought not to have been made.
The taxpayer appealed against the decision. The High Court judge allowed the appeal on the ground that the returns had not given rise to a debt as submitted by the Revenue.
HMRC appealed.
The Court of Appeal said the Chief Registrar had been correct to reject the application for annulment. The returns submitted by the appellant established the liabilities on which the statutory demand and bankruptcy order were based.
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