The burden of proof that there was manifest maladministration lay with the recipient and, according to the Court, he had failed to do so. According to the Court, the recipient had not made it plausible that X could or should have known that the zero rate did not apply. The Court took into account that, in view of the procedure regarding the additional assessment, this was not easy to interpret from a tax point of view. Furthermore, the recipient had not made it plausible that the administration was so incomplete or careless that this should lead to manifestly improper management.
Source: FUTD
