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One insufficiency in assessment relating to different errors did not validate the whole assessment for conduct and time limit purposes

By Mark McLaughlin, May 2026

In relation to discovery assessments which contained multiple insufficiencies of tax, the taxpayer had been overcharged to the extent that insufficiencies were not brought about carelessly or deliberately and/or that the extended time limits conditions were not met. 

Summary 

In relation to discovery assessments which contained multiple insufficiencies of tax, the taxpayer had been overcharged to the extent that insufficiencies were not brought about carelessly or deliberately and/or that the extended time limits conditions were not met. 

Background 

Following an enquiry, HM Revenue and Customs (HMRC) issued to the taxpayer (SH) a closure notice and various discovery assessments. SH&nbsp

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