FTTTx INCOME TAX – whether discovery assessment valid – share loss relief claim founded on extinction of company – whether claim invalid as a result of company’s restoration to the register – if not, whether new shares issued – if issued, whether for money or money’s worth – whether transferred to appellants – whether qualifying shares for share loss relief purposes – appeal on share loss relief dismissed and assessments upheld – appellants in receipt of interest – whether tax deducted by company – whether appellants entitled to credit for interest – held, no – whether penalty determinations can be raised when the discovery assessment did not rely on TMA s 29(4) – whether invalid because of manuscript amendments – whether appellants negligent – whether mitigation percentages should be changed – appeals dismissed and one penalty determination increased
[2014] UKFTT 980 (TC)
Bailii
England and Wales
Income Tax
Updated: 23 December 2021; Ref: scu.539001