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26/04/2009
Proprietary estoppel is the process by which the Court can recognise a party’s interest where it would be unfair to enforce the other’s strict legal rights.
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Should a lay trustee whose co-trustee was the Executor and Trust Company of a solicitor’s firm be entitled to argue that he had a reasonable excuse for the late payment of capital gains tax (CGT) on a share sale because HMRC had not drawn the payment on account feature to his attention?
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