INTRODUCTION
The issue of taxation has often generated controversies between the tax authorities on one hand and the taxpayers on the other. These controversies or disputes generally stem from the very nature of tax itself and the peculiar way in which taxing Statutes are interpreted by the Courts.
Taxes are levies imposed under the authority of the legislature and they are levied by a public body for public purposes.1 Tax is created by law and levied on individuals, incomes, commodities and transactions to yield public revenue that affords government the opportunity to offer protection and other socio – economic amenities to the citizens.2 It is one of the sources of income for government.3 Taxes are imposed by Statutes only.4 The issue of tax is consequently outside the ambit of common law. Therefore, for any individual to be chargeable to tax there must be a clear link between the charging provisions and the intended taxpayer. The link must be direct, not inferential.5 The insistence on the direct link between the charging provisions and the intended taxpayer has been a source of sustained controversies between the taxpayers and the tax authority
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