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Extended time limit discovery assessments were valid but some properties were held on constructive trusts

By Mark McLaughlin, June 2025

Discovery assessments were valid and benefited from the extended 20-year time limit, and unexplained bank deposits were untaxed company withdrawals, but contributions to the purchase of certain properties were made by a relative and friend as the taxpayer asserted, and some properties were held on constructive trusts. 

Summary 

Discovery assessments were valid and benefited from the extended 20-year time limit, and unexplained bank deposits were untaxed company withdrawals, but contributions to the purchase of certain properties were made by a relative and friend as the taxpayer asserted, and some properties were held on constructive trusts. 

Background 

The appellant was a director and shareholder of a limited company (PC), which was incorporated and started trading as a taxi company in 2006. It was based in London and was dissolved in 2015. In or around 2011, the company was

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