Interim protection in disputed tax recovery modified, with admitted demand payable and disputed balance kept in escrow.

The SC modified an interim order governing recovery of a disputed tax demand pending final disposal of the appeal. The department was allowed to continue raising demands so that limitation would not operate, the appellants were required to keep paying the admitted demand, and the disputed balance was to remain in an escrow account. Coercive recovery of the differential amount was barred unless leave of the Court was obtained.

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Issues: Modification of the interim order governing recovery of the disputed tax demand pending final disposal of the appeal.

Outcome: The interim order was modified. The department was permitted to continue raising demands to prevent limitation from operating, the appellants were directed to continue paying the admitted demand, and the disputed amount was to be kept in an escrow account with no coercive recovery of the differential amount without leave of the Court.

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