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M Jenner v HMRC

‘Fishing expedition’ not allowed

In M Jenner v HMRC [2022] UKFTT 203 (TC) (29 June) the FTT considered an appeal against an information notice issued to the taxpayer in the course of a self-assessment enquiry. 

HMRC opened enquiries into Mr Jenner’s tax returns for 2016/17 and 2017/18. They issued information notices to the taxpayer for both years against which he appealed. The notices sought information and documents in three categories.

  1. The first was details of household and personal expenditure including rent utilities food holidays etc. including explanations of how the expenditure was met.
  2. The second category was financial information including details of any director’s loan accounts and any sums drawn down from any trusts partnerships and other individuals.
  3. The final category was a schedule of all personal financial accounts together with bank and building society statements.

HMRC submitted that a review of the...

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