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Court of Appeal dismissed the appeals against summary judgments for tax arrears, affirming the High Court's decision in favor of the Collector General. The appellant's contention that the claims were insufficiently particularized due to discrepancies between the Notices of Estimation and the amounts claimed was addressed by admitting fresh evidence. This evidence, which explained the discrepancies as resulting from payments made by the appellant, led to the conclusion that there were no other defenses available to the appellant, and thus the original judgments were upheld.
Court of Appeal, summary judgment, tax arrears, PAYE/PRSI, income tax, Collector General, particularization, discrepancies, Notices of Estimation, Rules of the Superior Courts (RSC), O. 4, r. 4, O. 86A, r.4, Taxes Consolidation Act 1997, self-assessment, fresh evidence, appeal, Murphy criteria, finality of litigation, O'Malley principles, statutory interest, tax liability determination, administrative tribunal, judicial review.
Note: This is intended to be a fair and accurate report of a decision made public by a court of law. Any errors should be notified to the editor and will be dealt with accordingly.
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