If the Board1 is satisfied that at any time an undertaking given in respect of the property has not been observed in a material respect, the failure to observe the undertaking is a chargeable event with respect to the property. The person liable for the tax chargeable by reference to that event is the person who, if the property were sold at the time the tax becomes chargeable, would be entitled to receive (whether for his benefit or not) the proceeds of sale or any income arising from the proceeds2. Such a breach
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