... be regarded as constitutional. Key words Additional tax Burden of proof Constitution Deeming provisions Onus of proof Penalties Presumptions Reverse onus 1 Introduction Harold Wilson once remarked: Everybody should have an equal chance but they shouldn t have a flying start (Cohen 2000:150). His words...

...G.K. Goldswain Heavy penalties may be imposed on a defaulting taxpayer in terms of section 76(1) of the Income Tax Act, 58 of 1962 (the “Act”), unless “extenuating circumstances” are found to prevail, in which case any penalty imposed may be remitted partly or even in toto. This article examines...

... of penalties imposed by the judiciary were also analysed in previous articles in this research journal. These defences and pleas include reliance on a tax advisor, bookkeeper, accountant or member of staff and the conduct of the taxpayer before, during and after committing an offence. This article specifically...