An officer of HMRC was not prevented from making successive different discoveries in relation to the same tax liability, and an assessment in relation to the later discovery was valid. 

Summary

An officer of HM Revenue and Customs (HMRC) was not prevented from making successive different discoveries in relation to the same tax liability, and an assessment in relation to the later discovery was valid. 

Background

The appellant was a partner in a hedge fund. His accountants (F&L) introduced him to a company (NTA) which marketed tax avoidance schemes. The appellant wanted to avoid tax on his partnership income for 2007/08. NTA told the appellant about a scheme intended to generate artificial employment losses, unrelated to his partnership.