Decision No
 

PENALTY TAX -
 

estimated assessment - failure to object to assessment - whether ground for appeal against penalty tax assessment
 

failure to file return in time - attempt by taxpayer to comply - quantum of penalty
 

late filing tax return - quantum of penalty
 

restaurant business - purchase of premises used for restaurant business by saparate company - whether gain on subsequent sale of property subject to profits tax
 

onus of proof - claim by taxpayer that it had incurred interest payments
 

purchase and sale of property - whether profit subject to profits tax
 

appeal not genuine - costs awarded
 

taxpayer performing services outside of Hong Kong but visiting Hong Kong - whether part of a day comprises a complete day for tax purposes - s 8(1B) of the Inland Revenue Ordinance
 

lump sum payment - whether gratuity - whether payment subject to salaries tax
 

whether motor car expenses deductible for salaries tax purposes
 

diplomatic privilege - claim to be employed by international organisation
 

omission to include amount received - penalty of 5% - appeal frivolous - costs awarded of $1,000
 

source of income
 

lump sum payment - whether subject to salaries tax
 

lump sum payment - whether lump sum severance payment or payment for cancellation of service agreement
 

taxpayer suffering from serious illness - whether medical expenses can be deducted
 

Performance Gratuity Scheme - date when gratuity accrues due