HMRC met the burden of proving that items requested in an information notice were “reasonably required for the purpose of checking the taxpayer’s tax position” in connection with consultancy fees paid into the appellant’s bank accounts, which did not seem to have been included as the turnover of a related company. 

The appellant, a clinical consultant, had worked for NHS Trust hospitals in London and was on the teaching staff of Imperial College, London, while also running a private practice, for which clinical consultancy fees were received. The appellant retired from the NHS in 2020. He continued with Imperial College and his private practice. The appellant was the only director and the majority shareholder of a company (GRI).  

In July 2019, HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s self-assessment return for the tax year 2017/18. On 25 September 2019, HMRC requested details of