Summary
Assessments made against a deceased individual under the extended time limit provisions (TMA 1970, s 36(1A)(a)) were not set aside by reason of his death.
Background
The late taxpayer (MW) made a voluntary disclosure to HM Revenue and Customs (HMRC) in June 2010 of under-declarations of income for the tax years 2002/03 to 2007/08.
HMRC subsequently opened a Code of Practice 9 investigation into MW’s tax affairs. MW was to provide HMRC with a disclosure report on his tax affairs, but it was not produced. In August 2012, HMRC issued assessments for the tax years 1992/93 to 2005/06 inclusive, on the basis that MW’s tax returns for those years may be incorrect due to his deliberate or negligent behaviour. MW appealed. HMRC also sought penalties for all the years
