Dr S Easow v HMRC (and related appeals)

In Dr S Easow v HMRC (and related appeals) (TC02882 – 4 October) HMRC discovered that a doctor (E) had failed to declare income arising from offshore bank accounts. Following an enquiry they formed the opinion that E had significantly underdeclared his income for several years. They issued discovery assessments and imposed penalties at the rate of 50% of the potential lost revenue. The First-tier Tribunal reviewed the evidence in detail and found that E ‘was attempting to conceal information from HMRC: this was not merely negligent conduct but fraudulent conduct’. The Tribunal also found that ‘HMRC were justified in regarding the disclosed deposits of undeclared business income as merely examples of what was likely to be a more widespread practice’. The Tribunal upheld all the assessments and penalties. (The Tribunal also upheld assessments and penalties at the rate of 42.5%...