28When charge not paid during lifetime

28 When charge not paid during lifetime

Where, whether intentionally or not, a person escapes full payment of the charge in his lifetime by reason of not having duly made full, complete and accurate returns:

(a) the Commissioner shall have the same powers and remedies against the trustees of the estate of that person in respect of the liability to which that person was subject as he would have against that person if he were still living;

(b) the trustees shall make such returns as the Commissioner requires for the purpose of an accurate assessment;

(c) the trustees shall be subject to an additional charge to the same extent as the deceased person would be subject to an additional charge if he were still living, but the Commissioner may, in any particular case, for reasons which he thinks sufficient, remit the additional charge or any part thereof; and

(d) the amount of any charge payable by the trustees shall be a first charge on all the deceased person’s estate in their hands.