Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision.
The substantive appeal in J Addo v HMRC [2018] UKFTT 530 relates to discovery assessments issued by HMRC to Ms Addo under the TMA 1970 s 29 for the tax years 2009/10 and 2010/11. For the purposes of this article details of the arrangements under challenge by HMRC need not be considered.
Ms Addo’s grounds of appeal included whether the discovery assessments were validly issued and in particular:
whether a ‘discovery’ within the meaning of s 29(1) was made in her case; and
whether the conditions in s 29(5) were met (it being accepted by HMRC that Ms Addo’s return was not careless or deliberately incorrect within the terms of s 29(4)).
The burden of proof on the validity...
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Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision.
The substantive appeal in J Addo v HMRC [2018] UKFTT 530 relates to discovery assessments issued by HMRC to Ms Addo under the TMA 1970 s 29 for the tax years 2009/10 and 2010/11. For the purposes of this article details of the arrangements under challenge by HMRC need not be considered.
Ms Addo’s grounds of appeal included whether the discovery assessments were validly issued and in particular:
whether a ‘discovery’ within the meaning of s 29(1) was made in her case; and
whether the conditions in s 29(5) were met (it being accepted by HMRC that Ms Addo’s return was not careless or deliberately incorrect within the terms of s 29(4)).
The burden of proof on the validity...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
