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 
