Income from self-employment was under-declared for the year of HMRC’s tax return enquiry, and the ‘presumption of continuity’ applied to earlier tax years. 

On or around 31 January 2005, the appellant commenced his self-employment of removing household and garden rubbish from domestic properties, builders and other businesses. In March 2017, HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s self-assessment return for the tax year 2015/16.  

HMRC’s enquiry was prompted because the appellant’s return contained round figures (to the nearest £1,000) for income, expenses and profits. In HMRC’s view, the expenses were very high compared with other businesses. The profits chargeable to tax were always just above or, occasionally, just below the