An appeal against an information notice was allowed as HMRC had not produced evidence to show that it had reason to suspect the omission of income by the taxpayer.

HM Revenue and Customs (HMRC) wrote to inform the appellant that it was checking his tax position and requested various information in respect of the tax years 2012/13, 2013/14 and 2014/15. HMRC subsequently issued an information notice (under FA 2008, Sch 36), on the basis that there appeared to be a shortfall between the appellant’s income and expenditure.

The relevant items requested were: (1) A detailed listing of all shareholdings for the tax years ended 2012,