The High Court in Farrell & Sons (Garages) Limited v Revenue Commissioners [2024] IEHC 553 considered whether a taxpayer could overturn two tax settlements that it had entered into with Revenue in 1995. The settlements had been entered on foot of a tax audit that had commenced in 1994 and related to payments made through certain bank accounts. The plaintiff argued that it had subsequently (after 2014) discovered that those particular bank accounts had been fraudulently opened by third parties and sought to set aside the tax settlements. The plaintiff grounded its action on various claims of breach of contract, negligence, fraud and duress.
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