749. Officers of Revenue and Customs cannot create an estoppel; admission not conclusive.

An officer of HM Revenue and Customs cannot bind the Crown by entering into an agreement purporting to conclude tax and related questions for future years1, nor would such an agreement or any expression of opinion offered or course of action adopted by such an officer create an estoppel against the Crown2. The Crown is not estopped from denying the status of a fund as a charity by the consent of the Attorney General to an order setting up the fund where the whole understanding is that it is to be a charitable fund