Introduction
In August 2018, taxpayers were awakened to sudden freezing of
their bank accounts for alleged non-payment of taxes and this
marked the beginning of an "account- freezing" operation
by the Federal Inland Revenue Service (FIRS). Many taxpayers who
contemplated challenging the powers of the tax authority to direct
the freezing of their bank accounts were faced with the dilemma of
whether to approach the tax authorities to resolve the matter or to
go directly to the court for an interim order to reopen their
account.
Generally, tax disputes put taxpayers in precarious situations
as they are faced with a commercial dilemma of making prompt
business decisions in the face of uncertain tax positions. Thus,
speedy resolution of tax disputes is critical to any business.