Neil Pattullo v The Commissioners for HM Revenue and Customs: [2016] UKUT 0270 (TCC)
Upper Tribunal Tax and Chancery decision of Lord Glennie on 14 June 2016.
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CAPITAL GAINS TAX – Discovery assessment; tax avoidance scheme involving capital redemption policies; when HMRC officer discovered that assessment was insufficient; whether there can be a series of discoveries; whether the discovery became stale; TMA 1970 s 29(1); whether officer could not have been reasonably expected to be aware of the insufficiency at earlier date; attributes of the hypothetical officer; what constitutes such awareness; tests to be applied; TMA 1970 s 29(5); Appeal dismissed
Published 22 February 2017