[2001] EWCA Crim 1770
Where the defendant had secured a pecuniary advantage by underdeclaring the profits of his trade so as to evade income tax, a confiscation order in the amount of tax evaded, rather than in the amount of the undeclared profits, was not unduly lenient.
CA (Crim Div) (Mantell LJ, Rougier J, Grigson J)
27/07/2001