Jerome Anderson v The Commissioners for HM Revenue and Customs:[2018] UKUT 0159 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Morgan and Judge Berner on 17 May 2018.

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INCOME TAX 鈥 discovery assessment 鈥 s 29 TMA 鈥 meaning of 鈥渄iscover鈥 鈥 subjective and objective tests 鈥 whether Revenue officer believed that there had been an insufficiency of tax 鈥 whether officer merely had grounds for suspicion 鈥 whether it was open to officer to believe that there had been an insufficiency of tax 鈥 whether losses claimed to have arisen in a soccer academy trade were available for sideways loss relief 鈥 ss 64 and 72 ITA 鈥 whether taxpayer carried on a trade 鈥 whether on a commercial basis and with a view to or realistic expectation of profit 鈥 ss 66 and 74 ITA 鈥 whether tax-generated losses 鈥搒 74B ITA.

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Published 17 May 2018