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HMRC internal manual

Enquiry Manual

Working the Enquiry: Tax Cases: Woodrow (Executor of Charles D Woodrow) v Whalley 42TC249

Additional assessments were raised on a farmer for 11 years on his profits and untaxed income. The Commissioners found there had been undisclosed profits and the High Court upheld their findings with the exception of two sums paid into Mrs Woodrow’s deposit account.

The deceased had been unable to explain sums credited to his current account and Buckley J commented ‘that there was a considerable period during which an explanation could have been given, had the deceased been able to give a satisfactory explanation (p257).’