HMRC’s discovery assessment in respect of the high-income child benefit charge was validly made, and the taxpayer’s statement of case prepared with the assistance of AI did not provide grounds for allowing the taxpayer’s appeal.  

For the tax year 2018/19, the appellant had income in excess of his spouse, did not file a self-assessment tax return, had adjusted net income in excess of £50,000, and was in receipt of child benefit. On 23 April 2021, HM Revenue and Customs (HMRC) discovered that the appellant had not notified chargeability to the high-income child benefit charge (HICBC) for 2018/19 and that there was a loss of tax in respect of that tax year. Following communications between HMRC and the appellant, on 24 January 2023, HMRC issued a discovery assessment for 2018/19. The appellant appealed. 

The appellant contended that he should not suffer an HICBC tax charge for 2018/19. He put forward a variety of