Exercising discretion when applying to the court for a Council Tax Liability Order

Helen Barker made this Freedom of Information request to Bromsgrove District Council

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

The request was successful.

Dear Bromsgrove District Council,

The Council Tax (Administration and Enforcement) Regulations 1992 (the "Regulations") confer a duty on the billing authority to exercise discretion under regulation 34(1) when deciding whether to institute a complaint to the Magistrates' court to enforce payment.

Regulation 34(1) as amended by Regulation 15 of SI 1992/3008 states, with the relevant part emphasised, as follows:

"If an amount which has fallen due under paragraph (3) or (4) of regulation 23 (including those paragraphs as applied as mentioned in regulation 28A(2)) is wholly or partly unpaid, or (in a case where a final notice is required under regulation 33) the amount stated in the final notice is wholly or partly unpaid at the expiry of the period of 7 days beginning with the day on which the notice was issued, THE BILLING AUTHORITY MAY, in accordance with paragraph (2), apply to a magistrates' court for an order against the person by whom it is payable."

Regulation 34(2) states as follows:

"The application is to be instituted by making complaint to a justice of the peace, and requesting the issue of a summons directed to that person to appear before the court to show why he has not paid the sum which is outstanding."

The following are examples (but by no means exhaustive) of what are reasonable factors a recovery officer should take into account in exercising discretion to institute a complaint to the Magistrates court under paragraph (2) of regulation 34 of the Regulations:

1. the level of debt outstanding

2. any payments made subsequent to the full amount becoming due and time remaining of the financial year

3. are circumstances indicative of the debt being settled without resorting to enforcement

4. consider if enforcing the debt would unnecessarily subject the taxpayer to additional costs etc. and therefore amount to a penalty (see 3 above)

5. ensure monies have been prioritised to maintaining the in-year debt

6. allocate to the in-year any monies posted to arrears (or sufficient of it) that would if it had not been misallocated prevented the in-year liability also falling in arrears (see 5 above)

7. check for benefit claims or appeals already in the system and refrain from taking enforcement action where such genuine cases are unresolved

Q1. Does Bromsgrove District Council exercise discretion before proceeding under regulation 34(2) of the Council Tax (Administration and Enforcement) Regulations 1992 to request a summons from a justice of the peace (it may be an automated process)

Q2. If yes to (1) what factors are taken into consideration

Yours faithfully,

Helen Barker

foi BDC, Bromsgrove District Council

We regret that we are unable to deal with your freedom of information
request at this time. There is a huge amount of information about the
council available on its website and we would urge you to look at this
site first to find the answers to your questions.  Reports and minutes
considered by formal meetings of Council and its committees can be seen at
this [1]<link> and information about planning applications can be seen
[2]<here>.

 

Given the outbreak of coronavirus, the council is prioritising essential
services and we hope you will understand why dealing with freedom of
information requests is now not a priority. The outbreak has reduced
council staffing levels with the expectation that there will be an
increasing number of staff who are ill or self-isolating. Therefore, in
many cases, the staff who might know where to locate the information you
seek may simply not be available. Also, so far as “round robin” requests
from the media and think-tanks are concerned – particularly any that might
be to do with the council’s preparation for or response to coronavirus –
our priority has to be responding to the outbreak and keeping a limited
range of essential services running.

 

We will therefore not be providing responses to any freedom of information
requests received after 19th March 2020, beyond this generic
acknowledgement. We will review this situation at the end of May 2020
whether to extend this position. If you wish to resubmit your request
after we have ended the temporary suspension of the service, you are
welcome to do so and we will consider it at that time.

 

The Council’s media team is available to provide a comment on any specific
issue raised by the media in the usual way but this is not a route to
circumvent temporary suspension of responses to freedom of information
requests.

 

We have informed the Information Commissioner’s Office of our position and
advised them that we will also decline to deal with any complaints that
the ICO may receive as a result of the temporary suspension of this
service.

 

 

show quoted sections

References

Visible links
1. https://www.bromsgrove.gov.uk/council/th...
2. https://www.bromsgrove.gov.uk/planning-a...
3. mailto:[email address]
4. mailto:[Bromsgrove District Council request email]

Dear foi BDC,

Response to this request is long overdue. By law, under all circumstances, Bromsgrove District Council should have responded by now

Yours sincerely,

Helen Barker

foi BDC, Bromsgrove District Council

Dear Ms Barker,

During the period 20 March - 31 May 2020 Bromsgrove District Council were not processing Freedom of Information requests, and all requests received during that time were deleted.

People who submitted a request during that time received an automatic response asking them to resubmit their request when processing had restarted.

Processing has now restarted, so if you resubmit your request it will be processed in accordance with Freedom of Information regulations.

I hope this is satisfactory.

Kind regards,

Nicola

Nicola Brothwell
Information Support Officer, Business Development
Bromsgrove District & Redditch Borough Councils

Mon - Information Management all day
Tues – Info Mgmt 9-1, Legal 1:30 – 5
Wed – Legal all day
Thurs - Info Mgmt 9-1:30, Legal 2:00 – 5
Fri - Info Mgmt 9-1, Legal 1:30 – 5
Tel: 01527 881661
Email: [email address]
Bromsgrove District Council
Parkside,
Market Street,
Bromsgrove,
Worcestershire B61 8DA
www.bromsgrove.gov.uk

Redditch Borough Council
Town Hall,
Walter Stranz Square,
Redditch,
Worcestershire B98 8AH
www.redditchbc.gov.uk

View our privacy and fair processing notices –
Redditch:
http://www.redditchbc.gov.uk/council/cor...
Bromsgrove:
http://www.bromsgrove.gov.uk/council/cor...

show quoted sections

Dear foi BDC,

Request resubmitted.

Yours sincerely,

Helen Barker

foi BDC, Bromsgrove District Council

Dear Ms Barker,

I cannot find the request in the body of the email you sent - perhaps an attachment has been lost?

Please check and resubmit.

Thank you,

Nicola

Nicola Brothwell
Information Support Officer, Business Development
Bromsgrove District & Redditch Borough Councils

Mon - Information Management all day
Tues – Info Mgmt 9-1, Legal 1:30 – 5
Wed – Legal all day
Thurs - Info Mgmt 9-1:30, Legal 2:00 – 5
Fri - Info Mgmt 9-1, Legal 1:30 – 5
Tel: 01527 881661
Email: [email address]
Bromsgrove District Council
Parkside,
Market Street,
Bromsgrove,
Worcestershire B61 8DA
www.bromsgrove.gov.uk

Redditch Borough Council
Town Hall,
Walter Stranz Square,
Redditch,
Worcestershire B98 8AH
www.redditchbc.gov.uk

View our privacy and fair processing notices –
Redditch:
http://www.redditchbc.gov.uk/council/cor...
Bromsgrove:
http://www.bromsgrove.gov.uk/council/cor...

show quoted sections

Dear foi BDC,

https://www.whatdotheyknow.com/request/e...

Yours sincerely,

Helen Barker

foi BDC, Bromsgrove District Council

1 Attachment

Our Reference: 8590

 

Dear Ms Barker,

 

Thank you for your recent request for information.

 

Your request is being dealt with in accordance with the Freedom of
Information Act.  We will respond by 6 October 2020 at the latest.

 

Privacy Notice

 

The Council collects information, including personal information that you
provide about yourself and others, when you make a submission in relation
to a Freedom of Information (FOI) request.

 

The Council collects this information for the purpose of dealing with your
submission under the Freedom of Information Act 2000 and in accordance
with the legislation; a request made under the Freedom of Information Act
2000 is not a valid request unless it is in writing and includes the
following information:

 

o Enough of your real name to give anyone reading your request, a
reasonable indication of your identity.
o Where you are an agent working on behalf of someone else, the other
party will be interpreted as being the requestor therefore their
details are required.
o Valid address for correspondence (including postal or email).
o A description of the information you require, which may include
details of someone else.

 

The term ‘in writing’ covers requests submitted by letter and electronic
form, including those sent via the internet through social networking
sites such as Twitter and Facebook. Where a social media site is used to
submit a request, the real name may be visible within the user profile. If
you make the request public by publishing it on a website, as opposed to
sending a private message to the authority’s account, then we will
consider it within the requester’s reasonable expectations that the
authority will also publish its response on the site. 

 

Under FOI legislation, we have to maintain a log of requests. This
information is retained for 6 years.  All other information associated
with your request, such as the request, our acknowledgement, consultation
with the department involved, and our subsequent response to you is
retained for 2 years.

 

The council will not disclose your personal information to external
entities. We will also take steps to limit the amount of personal
information about you, is disclosed as part of any consultation process
regarding your request.

 

If you do not provide the appropriate details required under the
legislation, the information cannot be provided.  Other rights are not
affected.  These can be found [1]here.

 

This information will not be shared/sold to any other service/organisation
unless we have a duty to do so under law. This data will not be
transferred outside of the EEA.

 

No decisions around this data are made by automated means.

 

Kind regards,

Nicola Brothwell

Information Support Officer, Business Development

Bromsgrove District & Redditch Borough Councils

 

Mon - Information Management all day

Tues – Info Mgmt 9-1, Legal 1:30 – 5

Wed – Legal all day

Thurs - Info Mgmt 9-1:30, Legal 2:00 – 5

Fri - Info Mgmt 9-1, Legal 1:30 – 5

Tel: 01527 881661

Email: [2][email address]

Bromsgrove District Council Redditch Borough Council

Parkside, Town Hall,

Market Street, Walter Stranz Square,

Bromsgrove, Redditch,

Worcestershire B61 8DA Worcestershire B98 8AH

[3]www.bromsgrove.gov.uk [4]www.redditchbc.gov.uk

   

View our privacy and fair processing notices –

Redditch:

[5]http://www.redditchbc.gov.uk/council/cor...

Bromsgrove:

[6]http://www.bromsgrove.gov.uk/council/cor...

 

 

 

 

show quoted sections

References

Visible links
1. http://www.redditchbc.gov.uk/council/cor...
2. mailto:[email address]
3. http://www.bromsgrove.gov.uk/
4. http://www.redditchbc.gov.uk/
5. http://www.redditchbc.gov.uk/council/cor...
6. http://www.bromsgrove.gov.uk/council/cor...
7. mailto:[email address]
8. mailto:[Bromsgrove District Council request email]

foi BDC, Bromsgrove District Council

1 Attachment

Our Reference: 8590

 

Dear Ms Barker,

 

Thank you for your request for information. 

 

I am writing to inform you that the information you requested is not held.
Freedom of Information regulations give public access to recorded
information, but not to opinions, or to information that is not recorded
(for example, information in someone’s memory). If you would like more
detail on this, please see
[1]https://ico.org.uk/for-organisations/gui...
.

 

If you are dissatisfied with the way your request has been handled, you
have the right to request an internal review. 

 

If you are still dissatisfied following a review by the Council, you have
the right to complain to the Information Commissioner. You can contact the
Information Commissioner at:

 

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone 0303 123 1113

[2]https://ico.org.uk/

 

Kind regards,

Nicola Brothwell

Information Support Officer, Business Development

Bromsgrove District & Redditch Borough Councils

 

Mon - Information Management all day

Tues – Info Mgmt 9-1, Legal 1:30 – 5

Wed – Legal all day

Thurs - Info Mgmt 9-1:30, Legal 2:00 – 5

Fri - Info Mgmt 9-1, Legal 1:30 – 5

Tel: 01527 881661

Email: [3][email address]

Bromsgrove District Council Redditch Borough Council

Parkside, Town Hall,

Market Street, Walter Stranz Square,

Bromsgrove, Redditch,

Worcestershire B61 8DA Worcestershire B98 8AH

[4]www.bromsgrove.gov.uk [5]www.redditchbc.gov.uk

   

View our privacy and fair processing notices –

Redditch:

[6]http://www.redditchbc.gov.uk/council/cor...

Bromsgrove:

[7]http://www.bromsgrove.gov.uk/council/cor...

 

 

 

 

show quoted sections

References

Visible links
1. https://ico.org.uk/for-organisations/gui...
2. https://ico.org.uk/
3. mailto:[email address]
4. http://www.bromsgrove.gov.uk/
5. http://www.redditchbc.gov.uk/
6. http://www.redditchbc.gov.uk/council/cor...
7. http://www.bromsgrove.gov.uk/council/cor...
8. mailto:[email address]
9. mailto:[Bromsgrove District Council request email]

Dear foi BDC,

Can you please confirm that Bromsgrove District Council does not have anything written down (guidance, policy etc.) for staff to refer to when subjecting their customers to recovery of council tax, i.e. it is all in someone's memory and conveyed verbally to relevant officers?

Yours sincerely,

Helen Barker

foi BDC, Bromsgrove District Council

Our Ref: 8590

Dear Helen,

Please leave this with me and I will clarify the situation. I hope to respond to you by early next week.

Kindest regards

Julie Hemming-Smout
Information Support Officer, Bromsgrove District and Redditch Borough Councils

Tel: (01527) 64252, extension 3871
Email: [email address]

Bromsgrove District Council
Parkside,
Market Street,
Bromsgrove,
Worcestershire B61 8DA
www.bromsgrove.gov.uk

Redditch Borough Council
Town Hall,
Walter Stranz Square,
Redditch,
Worcestershire B98 8AH
www.redditchbc.gov.uk

show quoted sections

Dear foi BDC,

I have provided the response to Redditch Borough Council on the basis that it might also be appropriate here:

Thank you for your response. Since I submitted my request a number of anomalies have come to light regarding the enforcement procedure in the area concerned. However, I do not wish to pursue this, though the council might want to reconsider its actions regarding the recovery of Council Tax in light of the issues. Note later on under the heading 'NO LEGAL BASIS TO PURSUE LIABILITY ORDER ONCE AN AMOUNT AGREED' the point discussed is not a discretionary matter. I suggest this and the other points raised are considered by the Monitoring Officer, but that is of course a matter for the council.

It does not constitute discretion if a decision of whether to apply it or not depends on being prompted by the customer, parameters being agreed in advance relating to the outstanding monetary value of a customer's account or other information that can be input so the council tax processing system can detect it when running the complaint list. Discretion could only be appropriately applied at a stage when the summons is normally requested, i.e. when all the relevant circumstances are known about the customer's account at that particular time.

It is indicated from the council's website that discretion is not exercised at the point where a decision is needed to be made about whether to request a summons. Discretion is applied earlier than this, after a summons has been issued but before a liability order is obtained and after a liability order has been obtained, primarily to make payment arrangements which need to be monitored after the debt is secured by a liability order. The actual process of running the complaint list and the summonses is automated for which the defendant incurs disproportionate costs.

It is apparent from the council's website that the defendant incurs a £56.10 sum in respect of the council requesting the issue of a summons (an automated procedure). However, that sum actually covers the council's additional expenditure in respect of sending out reminders and officer time engaging with customers who query their accounts at this point. Also the same for final notices (see below) and after a summons has been issued in respect of customers who query their accounts to arrange payment plans which are conditioned, in the case of the latter, upon the council obtaining a Liability Order (to secure the debt). A total £84.70 court costs are added comprising summons costs of £56.10 plus a further £28.60 for the Liability Order. The £28.60 sum is added to the £56.10 costs already incurred for the request of the summons in respect of the accounts of all customers who have not paid the total amount outstanding of their liability before the court hearing, whether or not they take advantage of the pre-arranged payment plan. This is to compensate the council for the officer time attributed to making the application for a Liability Order (on day of the hearing).

Before the summons stage (final notice), a customer will be able to avoid summons costs, for example, a taxpayer who has lost her right to pay by instalments may have them effectively re-instated if she manages to agree a payment arrangement. Discretion whether to enter into a payment agreement with a taxpayer is applied again once the council has obtained a liability order (as an alternative to taking recovery action) but by that time she would have had the total £84.70 court costs added to the debt and included in the payment plan.

So the costs in reality cover the council's expenditure (additional to the issue of the summons) attributable to before the summons is requested, both after the summons is requested but before the liability order application and after the liability order has been obtained in respect of officer time engaging with customers who agree to enter into payment arrangements. The costs must therefore with absolute certainty cover the general administration of the council tax and enforcement departments.

RELEVANT LEGISLATION AND CASE LAW

I understand that the council must adhere to the Council Tax (Administration and Enforcement) Regulations 1992 and also be mindful of all established case law regarding the area concerned.

I am aware of a number of cases but particularly two which I would like to refer to regarding your response namely R (Nicolson) v Tottenham Magistrates [2015] EWHC 1252 (Admin) and Williams v East Northamptonshire [2016] EWHC 470 (Admin).

Williams v East Northamptonshire [2016] EWHC 470 (Admin)

The council's website states that if a summons is issued, this adds £56.10 court costs to the customer's account. I am making the assumption that the costs are actually added to the customer's account at this point because it is generally the approach taken by local authorities.

I am aware that in the East Northamptonshire case, the judgment went to some lengths to clarify the position with regard to when, i.e. at what stage it was permissible for a billing authority to add summons costs to a customer's account. In essence, what the judgment determined was that it was entirely lawful for the billing authority to inform the customer by stating on the summons the amount of costs it would ask for in the event it proceeded to make the application at court for a Liability Order. Implicit in this is that it is impermissible to add to the customers account at this point the costs claimed by the billing authority because there is only any legal basis to do so once the court has granted the Liability Order. The following in paragraph 28 of the judgment bears this out:

"...I have come to the clear conclusion that the summons is not an abuse of the process or otherwise invalid by reason of the fact that it includes reference to a claim for costs. The heading of the summons makes clear it seeks recovery of the Council Tax only. The complaint is therefore only as to the non payment of the Council Tax. The tax due is the Council Tax which is separately identified both on the first page and on the subsequent page. It is abundantly clear that the subject matter of the summons is therefore the recipient’s liability for the Council Tax...."

NO LEGAL BASIS TO PURSUE LIABILITY ORDER ONCE AN AMOUNT AGREED

The council's website effectively says that when a summons is issued, but before the Court hearing, it is possible to agree a payment arrangement but on the basis that the court will still be asked to grant a Liability Order (to secure the debt) and the payment plan will include the costs incurred in obtaining the Liability Order (£56.10 summons and £28.60 liability order).

These costs are incurred at a point after the customer has tendered payment. Therefore, the cost attributable to this activity could not lawfully be included in the costs claimed because expenditure may only be recharged that has been incurred by the authority up to the time of the payment or tender and clearly resources called upon by engaging staff in the matter would occur after payment was tendered. Expenditure incurred by the authority after that point falls on the wrong side of line to be referable to the summons and would only be lawfully recharged (if eligible) in respect of those who had not paid or tendered to the authority the aggregate of the outstanding amount and costs before the court hearing because only those customers may be proceeded against further and incur additional costs.

To be clear, it is not just the costs in these circumstances which are artificially inflated by either front loading or being charged where there is no legal basis at all which is a point of contention. The consequences are that for all those cases against whom the council proceeds in order to secure the debt once an amount has been agreed (the payment arrangement), the action is unlawful because regulation 34 of SI 1992/613 provides that the authority shall accept the amount and the application shall not be proceeded with in these circumstances.

Paragraph 34(5) of the regulations, are as follows (with emphasis):

“(5) If, after a summons has been issued in accordance with paragraph (2) but before the application is heard, there is paid or TENDERED to the authority an amount equal to the aggregate of—

(a) the sum specified in the summons as the sum outstanding or so much of it as remains outstanding (as the case may be); and

(b) a sum of an amount equal to the costs reasonably incurred by the authority in connection with the application UP TO THE TIME OF THE payment or TENDER,

the authority shall accept the amount and the application shall not be proceeded with.”

The authority could not defend its actions on the grounds that an arrangement does not constitute payment therefore it is entitled to obtain a liability order to secure the debt because the law does not say that the amount must be paid for the application not to be proceeded with, only that the amount tendered is accepted (the aggregate of the outstanding amount and costs). By agreeing a payment plan which encompasses the outstanding amount and costs (costs which are properly referable to the enforcement process) the authority has accepted the amount and so there is no legal basis to proceed to obtain a liability order from the Magistrates' court.

Notwithstanding the lack of provision to proceed once the aggregate of the outstanding amount and costs has been agreed by the council, even if it were permissible, these costs and any other incurred would have further criteria to meet for the court to be satisfied that they were reasonably incurred.

R (Nicolson) v Tottenham Magistrates [2015] EWHC 1252 (Admin)

The Tottenham case provides in the judgment some general guidance regarding Council Tax Liability Order court costs and give clues (paragraphs 35 and 46) as to what should not be included in the costs and an approach that might be legitimate in respect of averaging the costs.

“It is clear that there must be a sufficient link between the costs in question and the process of obtaining the liability order. It would obviously be impermissible (for example) to include in the costs claimed any element referable to the costs of executing the order after it was obtained, or to the overall administration of council tax in the area concerned.” (Paragraph 35)

"In principle, therefore, provided that the right types of costs and expenses are taken into account, and provided that due consideration is given to the dangers of double-counting, or of artificial inflation of costs, it may be a legitimate approach for a local authority to calculate and aggregate the relevant costs it has incurred in the previous year, and divide that up by the previous (or anticipated) number of summonses over twelve months so as to provide an average figure which could be levied across the board in "standard" cases.." (Paragraph 46)

However, the above does not go so far as to specify what the right types of costs and expenses are, plus the 1992 Council Tax Regulations (and associated guidance) also apply so any provisions in those capable of establishing what are "relevant costs" need taking into account. Crucially, the possibility that the approach of averaging the costs is conditional upon the right types of costs and expenses being taken into account and being mindful of the dangers of artificially inflating the costs.

Government guidance from 1993 and 2013 both provide within them that "the Court may wish to be satisfied that the amount claimed by way of costs in any individual case is no more than that reasonably incurred by the authority". They do so because the court is obliged to hear individually anyone wishing to raise a defence and regulation 35(1) of the Regulations provides that a single liability order may deal with one person and one amount.

The streamlining of the process, i.e. by hearing cases of all the defendants in a bulk application who decline the invitation to defend themselves would if the law was properly applied be met with a forfeiture of costs income because only expenditure which is common to every defendant may lawfully be included in a standard sum. For example, even if expenditure attributable to engaging with customers agreeing payment arrangements was not impermissible for the reasons discussed, they would not otherwise be deemed "relevant costs" to be included in the calculation because the expenditure is not common to every defendant but also because it would be impermissible to include in the costs any element referable to the overall administration of council tax in the area concerned (para 35, Tottenham judgment).

There is also the anomaly that the customers who to the greatest degree drive the level of activity are ironically avoiding the recovery process and not incurring any costs. These are generally those customers who have negotiated their instalments being re-instated, whilst customers who settle their debt without causing additional work are left subsidising this expenditure when bizarrely none is incurred in connection with their summonses.

Expanding further on the concept of "reasonably incurred". If the costs are to be recharged lawfully to the customer it must have been reasonable for the council to have incurred them. Any expenditure recharged to the customer in respect of costs has not been reasonably incurred which is attributable to activity carried out by the council above what is necessary to secure the court order. Obtaining the order is merely a formality and it functions simply as the vehicle empowering the council to make use of a range of enforcement measures to pursue monies owed should it be necessary once it is in place, so with that in mind and that applications are made en masse, then the vast majority of costs typically claimed by local authorities are not necessary in a process which amounts to no more than seeking permission from the court.

Expenditure attributable to work carried out, which is clearly by its nature referable to the overall administration (in the area of council tax concerned) would not by virtue of it coinciding with when the complaint is in progress be sufficient to link it to the actual process of obtaining the liability order. This is separable from any that is permissible to be included in the costs claimed and would need omitting from the calculation because it would not be reasonable to expect those paying them to subsidise general administration or to be exploited as a means of funding revenues/recovery staff - and - because it is not common to every defendant.

It is generally accepted by billing authorities that defences against the issue of a Liability Order at the court hearing which are considered to be valid are restricted to no more than a handful. However, there are seven obvious additional defences that would be valid if no discretion is exercised prior to requesting the issue of a summons and expenditure incurred by the council outside the process of applying for and obtaining a liability order is included in those costs. They would be that;

1. the billing authority has not (does not) comply with regulation 34(1) of the Council Tax (Administration and Enforcement) Regulations 1992;

2. expenditure amounting to £56.10 was not incurred by the council in respect of instituting the complaint;

3. the costs have been inflated to subsidise customers who opt to make payment in line with the pre-arranged payment plans;

4. the costs in respect of instituting the summons include expenditure which is incurred by the council after that action;

5. the costs have been inflated to subsidise expenditure incurred by the council in respect of potential applications to the court but which are not made by virtue of negotiations that have taken place to reinstate instalments;

6. the costs in general have been inflated to subsidise expenditure incurred by the council in respect of officer time monitoring arrangements and/or engaging with customers after the process of applying for and obtaining the liability order has ended; and

7. the costs in general have been inflated to fund the running of the council tax and enforcement departments and/or the overall administration of council tax in the area concerned.

Yours sincerely,

Helen Barker