The taxpayer’s appeal against various unidentified bank receipts treated by HMRC as additional income of profits was allowed in part.
The appellant was involved in a number of property development and property rental businesses. HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s tax return for the year ended 5 April 2008, and considered that rental income and capital gains had been omitted from his tax return for that year. HMRC also issued discovery assessments for the years ended 5 April 2006, 2007, 2009 and 2010.
The appellant did not provide all of the information necessary to enable HMRC to establish exactly the profits and gains from his property businesses. HMRC’s assessments (and amendment to the appellant’s tax return for the year ended 5 April 2008) were therefore based on HMRC’s ‘best judgement’. The appellant appealed.
The
