HMRC’s discovery assessments were valid and made in time; the appellant had not discharged the burden of proving that the assessments should be displaced or varied; and the quantum of related penalty assessments was confirmed. 

The appellant’s family operated a public house business. In January 2002, a public house was sold to the appellant’s brother (PH), which was managed by the appellant’s father (BH) until 2013. In October 2007, the appellant sold a property (HC) for £105,000, which was purchased for £45,000 in 2006. In March 2011, the appellant purchased a property from PH for £140,000. Between the tax years 2007/08 and 2015/16 there was no record of the appellant having filed any tax returns. In January 2017, HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s tax affairs. Subsequently, HMRC issued discovery assessments for 2007/08 to 2015/16, and related penalty assessments. The