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HMRC internal manual

Enquiry Manual

Reopening Earlier Years: Tax Cases: Rosette Franks (King Street) Limited v Dick 36TC100

This case illustrates that in appropriate circumstances a single proven omission can be sufficient for the Commissioners (now replaced by the tribunal) to conclude that the accounts for the year in question and all surrounding accounts are unreliable in their entirety. But there were aggravating factors which clearly suggested that the omission which the Inspector had managed to prove was not an isolated instance. Were this not so, then the decision might very well have gone the other way.