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Masoud Mirsamadi v HMRC

Ascertaining undeclared income

In Masoud Mirsamadi v HMRC [2015] UKFTT 0058 (3 February 2015) the FTT agreed with HMRC’s method of ascertaining undeclared income over several years.

Mr Mirsamadi was appealing against discovery assessments in respect of the years 2004/05 2005/06 and 2006/07 as well as closure notices for years 2007/08 2008/09 2010/11 and 2011/12.

HMRC had opened an enquiry into the 2007/08 tax year. Bank details showed unidentified deposits and that a property had been sold but no capital gains tax had been paid. In April 2013 HMRC calculated that there was a shortfall in the income which the appellant would have needed to maintain himself his two young children and his wife. Given the lack of information provided by Mr Mirsamadi HMRC had used the Office of National Statistics’ Living Cost and Food Survey to calculate the family’s expenditure....

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