In Mazurkiewicz the taxpayer lost his life savings in a Ponzi-type scheme and then faced a tax bill on interest the benefit of which he arguably never received. The First-tier Tribunal was however able to conclude that there were no receipts of interest. Whilst a 'just' decision the extent to which even a purposive approach allows for such a conclusion is open to debate. The case is of interest to tax advisers in general because it shows a Tribunal adopting the ‘modern’ approach to the construction of taxing statutes in a non-tax
