This case is in practical terms the first legitimate expectation case to get home from the taxpayers' perspective.
The proceeding started with multiple causes of action principally directed at the allegation that by relying on the IR 330 statements to their detriment the taxpayers had a legitimate expectation that IRD would not collect the tax due.
As mentioned in Colins J's judgment IRD agreed that if the taxpayers had honestly relied on the IR 330 statements then they would not seek to collect the debt. This was necessarily a decision under s 6 and 6A of the Tax Administration Act. The matter went to trial on that basis and the taxpayers won. Hence it is effectively the first case in which a taxpayer has been successful in reviewing the Commissioner in terms of estoppel.