Taxation law, which includes a regulation of the wide ranging powers of the Commissioner of Inland Revenue (CIR), is largely perceived as a specialist area with its own unique rules. It however shares an important attribute with other areas of law such as administrative law, constitutional law, industrial law and criminal law. This shared attribute is that, like these other areas of law, taxation law forms a significant part of public law. The law of taxation seeks to regulate the relationship between the state and the citizen as far as the impost and collection of tax revenues are concerned.