The facts leading to this appeal may be shortly summarized as follows. On 16 March 1985, the Inland Revenue Department ("the Revenue") made additional assessments in respect of the appellant's (taxpayer) income for the previous years of assessments for the following amounts: Year of Assessment 1959 for additional tax of$20.04 Year of Assessment 1961 for additional tax of$15,301.60 Year of Assessment 1963 for additional tax of$1,831.95 Year of Assessment 1964 for additional tax of$4,538.70 Year of Assessment 1965 for additional tax of$7,054.00 Year of Assessment 1966 for additional tax of$62,276.50 Year of Assessment 1968 for additional tax of$8,329.75 Total $99,352.54

It is notable from the above that the additional assessments were made retrogressively, the last mentioned year being a period of 16 years and the first mentioned date going right back to about 26 years from the date on which the actual additional assessments were computed. Notices of the assessments were posted to the appellant on the same date. On 21 December 1985, the Revenue took out a writ of summons against the taxpayer for a sum, which after the addition of penalties for late payments, amounted to $