Capital Gains Tax/Taxation of Chargeable Gains : Other – disposals of (a) a piece of land with dwelling to connected person and (b) another contiguous piece to developer – Code of Practice 9 investigation into returns for 2006-07 and 2007-08 on basis that (a) land disposal not returned and (b) that business assets taper relief may have been wrongly claimed – Schedule 36 notice issued and reissued – HMRC withdrawing case before appeal hearing – further notice with fewer requirements issued three months after withdrawal – whether res judicata applies – whether abuse of process -whether Condition B in paragraph 21 Schedule 36 (officer had reason to suspect loss of tax) met where no evidence from officer – whether decisions about s 20 TMA that there must be a sensible or reasonable prospect of HMRC making a valid discovery assessment applicable to Schedule 36 notices.
[2018] UKFTT 774 (TC)
Bailii
England and Wales
Capital Gains Tax
Updated: 13 December 2021; Ref: scu.632450
