Regulation 49 Assessments raised post IVA

X entered a voluntary arrangement in June 1996. At the supervisor's request, P35's etc. were submitted for years 5.4.93;94;95;96;97 and 98. The Revenue issued Reg49 assessments for each year citing X. Those within the IVA were confirmed at the Commisioners because X presented no information. The issues are these:-
1. Do the Reg 49's within the IVA period have any legality given the contractual nature of the IVA proposal which the Revenue supported;
2. Should the Regulation 49's been served on the VA Supervisor?
3. Should Reg 49 been used at all? The Supervisor has the power to bankrupt X if he does not cooperate in his VA.
Ben Clarke