The taxpayers, a married couple, traded in partnership until 1987, when they incorporated the business to a limited company.
In 1998, HMRC opened an investigation into the couple’s tax affairs: the department had received information suggesting the taxpayers had underdeclared their income for more than 20 years and that they had not disclosed income from money invested overseas.
HMRC issued assessments covering the period from 1982/83 to 2000/01.
The couple appealed.
The First-tier Tribunal said the husband was not ‘a credible witness’ and did not accept his evidence.
There had been undeclared cash sales for many years, the proceeds of which had been invested offshore.
The taxpayers had not disproved the assessments under appeal.
The case had been carried out properly by HMRC with information supplied to the taxpayers on a reasonable timescale.
The taxpayers’ appeals were dismissed.