Assessments on a company in respect of an overdrawn director’s loan account were upheld in the absence of any financial evidence to challenge them, and an appeal against an assessment on a director-shareholder on the writing-off of an overdrawn director’s loan account balance was also dismissed. 

The first appellant, a company (TSSF), was owned by the second appellant (PP) and his wife (Mrs P). PP was the sole director and had at all times exercised full control over TSSF. HM Revenue and Customs (HMRC) opened a compliance check in relation to TSSF on 11 February 2014, which culminated in a referral to HMRC’s Fraud Investigation Service, which offered the first appellant the opportunity to enter the contractual disclosure facility (CDF). The company’s agent submitted a CDF acceptance. 

In the subsequent disclosure report, the agent analysed PP’s director’s loan account (DLA) with the company for the