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                  The TAC found that the Appellant had not made a full and true disclosure of all material facts necessary for the making of an assessment of the chargeable income in his 2005 tax return. As a result of that finding, the TAC determined that the Appellant was not entitled to rely on the protective provisions of Section 955(2)(a) of the TCA 1997 and that the Respondent was not estopped from raising the Amended Assessment to income tax outside of the four-year time limit contained in Section 995.
                  It is from her determination about the Appellant brings this case stated.
                  On the 21 st of December 2005, the shareholders of Tramult , which included the Appellant and MMP Ltd, passed a special resolution amending the memorandum and articles of association of Tramult to increase the ordinary shares to 2,000,000, and then to allocate 152 ordinary shares of �1 each to MMP Ltd at a premium of �9,868 per share, totaling �1,500,000. Tramult allocated 304 ordinary shares of �1 each between 5 individuals, one of whom was the Appellant.
                  Rights attaching to the ordinary shares of Tramult moved or transferred to the ordinary shares of the company, that is to say from the ordinary shares held by MMP Ltd to the ordinary shares held by the Appellant and other ordinary shareholders.
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