HMRC assessments and penalties were upheld after a business was found to have operated a second undisclosed bank account and suppressed cash takings.

The appellant operated a Thai restaurant as a sole trader. HM Revenue and Customs (HMRC) conducted a ‘test meal’ at the restaurant on 11 February 2016. HMRC subsequently opened an enquiry into the appellant’s tax return for 2014/15 and requested information and documents relating to the restaurant. HMRC later also opened an enquiry into the appellant’s tax return for 2015/16.