The court heard an appeal against a preliminary decision of the Special Commissioners about two issues of principle which affect forthcoming appeals against assessments to self-assessments made by the Respondent Commissioners against them. The two issues are: (a) whether the time limit imposed by section 34 of the 1970 Act (‘TMA’) applies to closure notices … Continue reading Morris and Another v Revenue and Customs: ChD 23 May 2007
FTTTx INCOME TAX – self assessment – closure notices – discovery assessments – whether business records adequate – whether sales omitted – whether full disclosure of bank accounts – onus of proof – presumption of continuity – Taxes Management Act 1970 ss. 9A, 12B, 28A, 29, 34, 36, 49G, 50 and 95; Finance Act 2007 … Continue reading Allan v Revenue and Customs (Income Tax/Corporation Tax : Assessment/Self-Assessment): FTTTx 20 Jul 2016
The court considered the standard of proof required before the Commissioners when considering the application of penalties.
Held: When challenging the assessment of a penalty on a taxpayer, there was no reason why the normal civil standard of . .