HMRC had reasonably considered that funds deposited in private bank accounts held in the UK and Isle of Man were undeclared income from a trade; the appellant had failed to declare foreign income; discovery assessments were validly made; and the appellant’s deliberate behaviour justified longer assessment time limits. 

The appellant was registered for self-assessment in the UK from 28 February 1997. None of the tax returns filed for the tax years in question indicated that the appellant was non-UK resident. The appellant operated a property management business. Initially, he traded as a sole proprietor, subsequently as a partnership and finally through an incorporated entity (ARCL). Following a compliance check, HM Revenue and Customs (HMRC) contended that the appellant had failed to fully declare the income from his trade prior to the incorporation of ARCL and then continued to run an off-record trade as a sole proprietor in parallel to the