Byrne v Revenue and Customs (CLOSURE NOTICES - records - burden of proof) [2023] UKFTT 293 (TC) (09 March 2023)
The Appellant failed to provide documentary or oral evidence to displace HMRC’s figures, which were based on third-party records and best judgment. The burden of proof was not discharged by the Appellant, so the Closure Notices and amendments stand.
- Citation
- [2023] UKFTT 293 (TC)
- Parties
- Appellant: Christopher Byrne; Respondents: The Commissioners for His Majesty’s Revenue and Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 09 March 2023
- Procedural Posture
- Tax Appeal / First Tier Tribunal Decision
- Outcome
- Appeal dismissed
- Legal Topics
- Closure Notices, Self Assessment Tax Returns, Burden of Proof, Business Records, Best Judgment Assessment
Case Brief
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Parties
Christopher Byrne
Appellant
The Commissioners for His Majesty’s Revenue and Customs
Respondents
Procedural Posture
Tax Appeal / First Tier Tribunal Decision
Legal Issues
- 1 Whether the Closure Notices and amendments to the Appellant’s SATRs for 2016/17, 2017/18, and 2018/19 are correct
- 2 Whether the Appellant discharged the burden of proof to show HMRC’s conclusions were incorrect
Ratio Decidendi
The Appellant failed to provide documentary or oral evidence to displace HMRC’s figures, which were based on third-party records and best judgment. The burden of proof was not discharged by the Appellant, so the Closure Notices and amendments stand.
Court Disposition
Appeal dismissed
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