An HMRC enquiry into the tax return of a self-employed taxpayer resulted in additional taxable profits for the tax year of enquiry, and for other tax years under the ‘presumption of continuity’, and penalties were also chargeable.
The appellant was a self-employed financial adviser. HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s self-assessment return for the tax year 2008/09. HMRC raised enquiries concerning certain unexplained deposits in the bank accounts of the appellant and his wife in 2008/09.
The appellant’s explanation of the unexplained deposits was unsatisfactory to HMRC, and an assessment of additional profits was subsequently made for 2008/09. In addition, HMRC raised assessments for the tax years 2006/07, 2007/08, 2009/10, 2010/11 and 2011/12. In each case, HMRC increased the appellant’s taxable business profits by reference to the estimated figure used in the
