Discovery assessments and penalties were cancelled as HMRC had not identified any taxable sources of income to which the amounts assessed could relate, and the charging provisions on ‘miscellaneous income’ could not apply to cover amounts which HMRC considered the appellant to have received.
Summary
Discovery assessments and penalties were cancelled as HM Revenue and Customs (HMRC) had not identified any taxable sources of income to which the amounts assessed could relate, and the charging provisions on ‘miscellaneous income’ (in ITTOIA 2005, s 687) could not apply to cover amounts which HMRC considered the appellant to have received.
Background
HMRC opened an investigation in February 2013 inviting the appellant to make full disclosure under the contractual disclosure facility. The appellant declined to make any admission but agreed to
