INCOME TAX – discovery assessment – s 29 TMA – meaning of ‘discover’ – subjective and objective tests – whether Revenue officer believed that there had been an insufficiency of tax – whether officer merely had grounds for suspicion -whether it was open to officer to believe that there had been an insufficiency of tax – whether losses claimed to have arisen in a soccer academy trade were available for sideways loss relief – ss 64 and 72 ITA – whether taxpayer carried on a trade – whether on a commercial basis and with a view to or realistic expectation of profit – ss 66 and 74 ITA – whether tax-generated losses -s 74B ITA
Citations:
[2018] UKUT 159 (TCC)
Links:
Jurisdiction:
England and Wales
Income Tax, Taxes Management
Updated: 22 April 2022; Ref: scu.616366