The Commissioners for HM Revenue and Customs v Dr Michael Charlton and Mrs Barbara Corfield (executrix of Mr J Corfield DECEASED): [2012] UKFTT 770 (TCC

Upper Tribunal Tax and Chancery decision of Mr Justice Norris and Judge Berner on 20 December 2012.

Read the full decision in The Commissioners for HM Revenue and Customs v Dr Michael Charlton, Mrs Barbara Corfield, Mrs Barbara Corfield (executrix of Mr J Corfield DECEASED): [2012] UKFTT 770 (TCC.

Capital Gains Tax – whether discovery assessments valid – s 29, Taxes Management Act 1970 - meaning of “discovery” – inference of information under s 29(6)(d)(i) – inclusion of DOTAS scheme reference number in return - whether an officer could not have been reasonably expected to be aware of an insufficiency of tax (s 29(5)) – nature of the hypothetical officer.

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