Silvester v Revenue and Customs (Income Tax/Corporation Tax : Losses): FTTTx 30 Oct 2015

FTTTx INCOME TAX – loss relief for farming losses – whether restriction on loss relief in section 67 Income Tax Act 2007 only applies to ‘hobby’ farming – no – whether Appellant’s farming activities met the ‘reasonable expectation of profit’ test in section 68 Income Tax Act 2007 – no – discovery assessment under section 29 Taxes Management Act 1970 – whether officer of HMRC could reasonably have been expected to be aware of information in previous years’ tax returns – no – appeal dismissed
References: [2015] UKFTT 532 (TC)
Links: Bailii
Jurisdiction: England and Wales

Last Update: 15 October 2020; Ref: scu.556174