Mukuna v Revenue and Customs (INCOME TAX - HMRC allege overclaim of expenses - rodent infestation resulting in absence of evidence to justify expenditure - discovery assessments - validity - extended time periods - closure notices - valid - penalty for deliberate overclaim) [2025] UKFTT 1020 (TC) (21 August 2025)

Mukuna v Revenue and Customs (INCOME TAX - HMRC allege overclaim of expenses - rodent infestation resulting in absence of evidence to justify expenditure - discovery assessments - validity - extended time periods - closure notices - valid - penalty for deliberate overclaim) [2025] UKFTT 1020 (TC) (21 August 2025)

The appellant failed to provide any credible or documentary evidence to support his expense claims, and the amounts claimed were inconsistent and implausible. The tribunal found the discovery assessments and closure notices valid, and the penalty for deliberate inaccuracy properly imposed, as the appellant's behaviour was deliberate in seeking to mislead HMRC.

Citation
[2025] UKFTT 1020
Parties
Appellant: Moses Mukuna; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
21 August 2025
Procedural Posture
Income Tax Appeal / First Tier Tribunal (tax Chamber) Final Judgment
Outcome
Appeal dismissed
Legal Topics
Income Tax, Discovery Assessments, Closure Notices, Penalties for Deliberate Inaccuracy, Deductible Expenses, Burden of Proof, Validity of Assessments
Tax Law Income Tax Discovery Assessments Closure Notices Penalties for Deliberate Inaccuracy Deductible Expenses Burden of Proof Validity of Assessments

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Parties

Moses Mukuna

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Income Tax Appeal / First Tier Tribunal (tax Chamber) Final Judgment

Legal Issues

  1. 1 Whether the discovery assessments issued by HMRC for tax years 2016/2017-2018/2019 were valid under section 29 TMA
  2. 2 Whether closure notices for 2019/2020-2021/2022 were valid and correct
  3. 3 Whether the appellant incurred deductible expenses as claimed

Ratio Decidendi

The appellant failed to provide any credible or documentary evidence to support his expense claims, and the amounts claimed were inconsistent and implausible. The tribunal found the discovery assessments and closure notices valid, and the penalty for deliberate inaccuracy properly imposed, as the appellant's behaviour was deliberate in seeking to mislead HMRC.

Court Disposition

Appeal dismissed

Orders

  • Discovery assessments upheld
  • Closure notices upheld