Gone away

A sole trader owned a Thai restaurant between May 2002 and September 2003. HMRC opened an enquiry into his tax returns for 2002-03 and 2003-04. After observing the restaurant HMRC said that drinks takings had been under declared. A jeopardy assessment was made for each year and closure notices issued.

The taxpayer appealed to the General Commissioners. The figures were revised but it was discovered that the takings for September 2002 were not included. The tax was recalculated.

Meanwhile the taxpayer had vanished and was believed to have returned to an unknown address in Thailand. The Special Commissioner therefore made a direction under the Special Commissioners (Jurisdiction and Procedure) Regulations 1994 SI 1994/1811 reg 28 dispensing with the need to serve on the taxpayer documents relating to the appeal.

The Special Commissioner found that HMRC's figures had been carefully calculated. It was for the taxpayer...