Johnson v Revenue and Customs: FTTTx 19 Jun 2012

FTTTx INCOME TAX – losses – Set off of losses against general income -Section 380 ICTA 1988 – Restriction on set off under Section 384 (6)ICTA in relation to provision of ‘plant and machinery for leasing in the course of a trade’ -Whether losses in relation to business involving yacht so restricted -Yes – Whether appellant negligent for purposes of showing pre-condition for discovery assessment under Section 29 TMA 1970 – No -Whether officer could not have been reasonably expected on basis of information available to him to be aware of insufficiency of tax assessment – Yes- Appeals against assessment for 2004-5, 2005-6, and 2006-7 dismissed -appeal against assessment for 2003-4 allowed on grounds discovery assessment out of time

Citations:

[2012] UKFTT 399 (TC)

Links:

Bailii

Income Tax

Updated: 03 November 2022; Ref: scu.462805