The Commissioners for HM Revenue and Customs v Dr Michael Charlton and Mrs Barbara Corfield (executrix of Mr J Corfield DECEASED): [2012] UKFTT 770 (TCC

Upper Tribunal Tax and Chancery decision of Mr Justice Norris and Judge Berner on 20 December 2012.

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 1 December 2016

• Category: Tax
• Release date: 20 December 2012

Read the full decision in The Commissioners for HM Revenue and Customs v Dr Michael Charlton, Mrs Barbara Corfield, Mrs Barbara Corfield (executrix of Mr J Corfield DECEASED): [2012] UKFTT 770 (TCC.

Capital Gains Tax – whether discovery assessments valid – s 29, Taxes Management Act 1970 - meaning of “discovery” – inference of information under s 29(6)(d)(i) – inclusion of DOTAS scheme reference number in return - whether an officer could not have been reasonably expected to be aware of an insufficiency of tax (s 29(5)) – nature of the hypothetical officer.

Published 1 December 2016