Pattullo v Revenue and Customs: FTTTx 26 Aug 2014

FTTTx CAPITAL GAINS TAX – Discovery assessment; tax avoidance scheme involving capital redemption policies; whether HMRC officer discovered that chargeable gains ought to have been assessed or relief refused, whether an assessment was insufficient, or whether any relief given was excessive; whether officer of HMRC could not have been reasonably expected to be aware of the chargeable gains, insufficiency or excess relief; TMA 1970 s 29; what constitutes such awareness; tests to be applied; Res Judicata and judicial review proceedings; abuse of process; application to set aside Direction refusing to allow Grounds of Appeal to be amended; The Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 Rule 6(5); Appeal dismissed

[2014] UKFTT 841 (TC)
Taxes Management Act 1970 29
England and Wales

Capital Gains Tax

Updated: 11 November 2021; Ref: scu.536405