Goudie v Revenue & Customs [2010] UKFTT 552 (TC) (05 November 2010)
The Appellant failed to discharge the burden of proof to explain the origin of deposits in the Woolwich account; HMRC's amendments, assessments, and penalty determinations were justified based on unexplained deposits reasonably representing undeclared income and negligent conduct.
- Citation
- [2010] UKFTT 552 (TC)
- Parties
- Appellant: Anthony Goudie; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 05 November 2010
- Procedural Posture
- Tax Appeal / Final Judgment
- Outcome
- Appeal dismissed
- Legal Topics
- Income Tax, Corporation Tax, Self Assessment, Discovery Assessments, Penalties
Case Brief
Summary, issues, holding and outcome
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Parties
Anthony Goudie
Appellant
The Commissioners for Her Majesty’s Revenue and Customs
Respondents
Procedural Posture
Tax Appeal / Final Judgment
Legal Issues
- 1 Whether unexplained deposits in the Woolwich account constituted undeclared taxable income
- 2 Whether HMRC's amendments and assessments were excessive
- 3 Whether penalty determinations under section 95 TMA were justified
Ratio Decidendi
The Appellant failed to discharge the burden of proof to explain the origin of deposits in the Woolwich account; HMRC's amendments, assessments, and penalty determinations were justified based on unexplained deposits reasonably representing undeclared income and negligent conduct.
Court Disposition
Appeal dismissed
Orders
- Amendments to self-assessment returns for years ended 5 April 2005 and 2006 confirmed
- Discovery assessments for years ended 5 April 2003 and 2004 confirmed
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