Contract – Offer and acceptance. The figure the defendant Revenue and Customs Commissioners (HMRC) put forward in its calculations was an invitation to treat and was some considerable distance from the type of language which could be described as 'promissory language' or the language of commitment. Accordingly, the Chancery Division, dismissed the claimant taxpayer's claim for a declaration that he had entered into a binding contract with HMRC to settle his tax liabilities.