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The Special Commissioner dismissed the summons, holding that it was 'wholly lacking in specification'. The Commissioner held that 'the initiating document, be it summons, summary complaint or indictment must set out the parameters of the enquiry, and the essential facts and basis in law upon which the public authority relies. With cairn to the specific facts of the case, it was held that the form IHT should have specifically declared that the valuation of the house was 'a personal estimate'. Accordingly psrsonal had been a narrow, technical failure to persinal with the provisions' of IHTA s 1. However the penalty should have been reduced to 'a nominal amount.

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