Ross McInally v Revenue & Customs (INCOME TAX/CORPORATION TAX : Assessment/self-assessment) [2016] UKFTT 506 (TC) (18 July 2016)

Ross McInally v Revenue & Customs (INCOME TAX/CORPORATION TAX : Assessment/self-assessment) [2016] UKFTT 506 (TC) (18 July 2016)

The Tribunal found that while some unidentified receipts could be treated as taxable income, not all assessments by HMRC were justified. The appeal was allowed in part, reflecting a partial acceptance of the appellant's position.

Source-derived case information.

Citation
[2016] UKFTT 506 (TC)
Parties
Appellant: Ross McInally; Respondent: Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
18 July 2016
Procedural Posture
Income Tax/corporation Tax Assessment/self Assessment Appeal / First Tier Tribunal (tax) Decision
Outcome
Appeal allowed in part
Legal Topics
Income Tax, Corporation Tax, Self Assessment, Discovery Assessments, Burden of Proof
Tax Law Income Tax Corporation Tax Self Assessment Discovery Assessments Burden of Proof

Source-derived case record

Summary, issues, holding and outcome

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Parties

Ross McInally

Appellant

Revenue & Customs

Respondent

Procedural Posture

Income Tax/corporation Tax Assessment/self Assessment Appeal / First Tier Tribunal (tax) Decision

Legal Issues

  1. 1 Whether closure notice amending self-assessment was valid
  2. 2 Whether discovery assessments were justified
  3. 3 Whether unidentified receipts should be treated as taxable income

Ratio Decidendi

The Tribunal found that while some unidentified receipts could be treated as taxable income, not all assessments by HMRC were justified. The appeal was allowed in part, reflecting a partial acceptance of the appellant's position.

Court Disposition

Appeal allowed in part

Orders

  • Some assessments amended or reduced
  • Some unidentified receipts not treated as taxable income