Victoria Carter & Peter Kennedy v The Commissioners for HM Revenue and Customs [2021] UKUT 0300 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Rupert Jones and Judge Andrew Scott on 01 December 2021
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STAMP DUTY LAND TAX – discovery assessment – paragraph 30(3)(a) of Schedule 10 to the Finance Act 2003 – whether FTT erred in deciding a hypothetical officer of HMRC could not have been reasonably expected to be aware that an assessment to tax was insufficient on the basis of the information made available when the enquiry period closed – appeal dismissed