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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Working the Enquiry: Tax Cases: Horowitz v Farrand 33TC221

Horowitz was a director of, and held 340 of the 350 shares, in a company which took over the business from him in 1930, but the Case 1 additional assessments for years 1942-43 to 1948-49 were made on Horowitz personally. He accounted for his investments by a cash hoard, betting and the sale of personal effects, but could produce no evidence. He also questioned the figures of living expenses contended for by the Inspector.

The Commissioners were not satisfied that around £11,000 came from non-taxable sources and determined the assessments accordingly.

In the High Court, the Judge merely said he could see no grounds for allowing the appeal.