Madden v Revenue and Customs (Income Tax/Corporation Tax : Assessment/Self-Assessment): FTTTx 26 Jul 2018

INCOME TAX – Self Assessment – tax fraud – COP9 investigation procedure – closure notices and discovery assessments – extension of time-limits to 20 years – ss. 9A, 28A, 29, 36, 50 of TMA – penalty determinations and assessments – s 95 TMA; Sch 24 FA 2007; Sch 55 FA 2009 – onus of proof as regards competence and time limit issues – onus of proof concerning quantum – whether assessments stand good; yes – penalty determinations and assessments – whether ‘negligent’ and ‘deliberate’; yes – whether penalty reduction for disclosure sufficient; yes – appeal dismissed
[2018] UKFTT 414 (TC)
Bailii
England and Wales

Updated: 01 August 2021; Ref: scu.621416