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 credible or consistent evidence of incurring deductible expenses. The discovery assessments and closure notices were validly issued under section 29(5) TMA, and the penalty for deliberate inaccuracy was properly imposed as the appellant knowingly claimed expenses he did not incur.

Citation
[2025] UKFTT 1020 (TC)
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, Deductibility of Employment Expenses
Tax Law Income Tax Discovery Assessments Closure Notices Penalties for Deliberate Inaccuracy Deductibility of Employment Expenses

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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 appellant incurred deductible employment expenses for the relevant tax years
  2. 2 Whether HMRC's discovery assessments and closure notices were validly issued
  3. 3 Whether the penalty for deliberate inaccuracy was properly imposed

Ratio Decidendi

The appellant failed to provide credible or consistent evidence of incurring deductible expenses. The discovery assessments and closure notices were validly issued under section 29(5) TMA, and the penalty for deliberate inaccuracy was properly imposed as the appellant knowingly claimed expenses he did not incur.

Court Disposition

Appeal dismissed

Orders

  • Discovery assessments and closure notices upheld
  • Penalty for deliberate inaccuracy upheld