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Dismissing the appeal and praising the ruling of Mr Justice Morgan, the judge asked: ‚What sensible purpose could be served by this court repeating in its judgments detailed discussions of every point raised in the grounds of appeal and the skeleton arguments when they have already been dealt with correctly and in detail in the judgment under appeal. No purpose at all, in my view. ‚ He said it was a case in which this court was justified in following the ‚excellent lead‚ of Lord Wilberforce in Brumby v Milner (1975) 51 TC 583. In a one-page tax opinion, with which the other members of the Appellate Committee agreed with only minor additions, Lord Wilberforce said he would not attempt a detailed analysis or refer to such authorities as might possibly be relevant, since that had been done to his complete satisfaction by the Court of Appeal affirming the judgment of Walton J. Mummery LJ said: ‚It has been said, more in jest than with justice, that ‚officials create work for other officials‚ and that bureaucracies generate work to justify their continued existence. Judges are not officials.

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