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 .

Capital Gains Tax 鈥 whether discovery assessments valid 鈥 s 29, Taxes Management Act 1970 - meaning of 鈥渄iscovery鈥 鈥 inference of information under s 29(6)(d)(i) 鈥 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)) 鈥 nature of the hypothetical officer.

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Published 1 December 2016