John Hargreaves v The Commissioners for HM Revenue and Customs: [2014] UKUT 0395 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Nugee on 8 September 2014.

Read the full decision in John Hargreaves v The Commissioners for HM Revenue and Customs: [2014] UKUT 0395 (TCC).

Procedure – preliminary issue – Capital Gains Tax – appeal against discovery assessment on basis both that HMRC not competent to make assessment and that taxpayer not in fact resident during year of assessment – whether competence of HMRC to make discovery assessment should be heard as a preliminary issue – s. 29 Taxes Management Act 1970.

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