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HMRC internal manual

Enquiry Manual

Working the Enquiry: Tax Cases: Yoannou v Hall 53TC32

Personal and private expenditure was alleged to have been met by £10,000 brought to the United Kingdom from Cyprus in 1954, by a loan of £3,000 from a friend who did not require repayment, from Social Security benefits and `a little money here and there’. The General Commissioners did not accept these explanations and determined assessments on furnished lettings in favour of the Revenue.

The decision was upheld in the High Court, where Fox, J, said

‘The Commissioners, it seems to me, were perfectly entitled to come to the conclusion that somebody who has had no national assistance since the late 1950s, who says he brought £10,000 into this country and that he had also been assisted in living by a loan of £3,000 from somebody who does not want it back, and who says that various persons living on his premises from whom payments were received were not tenants but just friends and relations, had not satisfied them that he was overcharged.’.