The tax inspector had sought to make an assessment outside the six year period, saying that the accounts had been prepared negligently. The taxpayer had claimed roll-over relief.
Held: The fact that the inspector had relied on professionally drawn accounts without investigating them further at the time was not a reason to disallow a reopening of the accounts. The inspector had been entitled to rely upon the accounts at the time. They did not cease to have been prepared negligently only because the tax inspector had accepted them.
England and Wales
Updated: 09 May 2022; Ref: scu.228427