In this judgment the Court of Appeal (McDonald J (judgment) with Pilkington J and O’Moore J (concurring)) considered an appeal from the High Court. The history of the case was protracted, with the underlying facts concerning a notice of opinion issued on 12 November 1998 under s811 TCA 1997 to challenge a tax advantage in the sum of £31,252.80 claimed in respect of partnership film losses for the tax year 1996/1997. The appellant lost his s811(7) appeal before the Appeal Commissioners and the Circuit Court (in 2004). A High Court case stated was withdrawn pursuant to a settlement dated 16 October 2012, under which the appellant agreed to be bound by the Circuit Court judgment. Revenue subsequently treated the notice of opinion as final and conclusive, withdrew the loss relief and issued an amended notice of assessment for €34,583.70. The appellant sought to re-litigate the matter and appealed on the basis of time-limit arguments under ss955 and 956 TCA 1997, as well as appealing the inspector’s refusal under s933(1)(c). Revenue relied on s811(5)(d) and s811(5A) to say that his routes of appeal were barred.