INCOME TAX – Appellant last working as a doctor in 1998 – Appellant claiming trade loss relief in tax years 2006/07, 2007/08 and 2008/09 in respect of legal expenses to challenge decisions of the General Medical Council regarding his registration as a medical practitioner and continuing medical education expenses -Whether Appellant ‘carried on a trade’ in the tax years in question (Income Tax Act 2005 s.64(1)(a)) – no – Discovery assessments issued in respect of tax years 2006/07 and 2007/08 (Taxes Management Act s.29) – Whether there had been a ‘discovery’ given that the Appellant disclosed his circumstances in his tax returns – No – Closure notice issued in respect of the 2008/09 tax return – Whether Appellant had a legitimate expectation that the trade loss relief would be allowed – No – Appeal allowed in part
Citations:
[2011] UKFTT 573 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 03 September 2022; Ref: scu.449477
