STEPHEN JOHN MULLENS v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2023] UKUT 00244 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Richards and Judge Andrew Scott on 02 October 2023
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INCOME TAX – whether the FTT erred in its application of the burden of proof to assessments made within the extended time limit provided by s.36 of TMA – no – whether, if an appeal against an assessment to tax has been dismissed, HMRC nonetheless have a burden to prove the loss of tax in making a penalty assessment – no – appeal dismissed