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A self-employed doctor sees patients at three NHS hospitals. He also works at home – writing up notes preparing invoices maintaining confidential patient records etc.
There are no facilities whatsoever at the hospitals for this essential part of his profession on which he spends considerable time during evenings weekends and some days when not visiting the hospitals.
He has a dedicated room at home in which he keeps a computer medical books and journals and general professional equipment. We have always said – see Horton v Young 47 TC 60 – that the home was the business base and claimed the cost of motor vehicle journeys to the three hospitals visited.
HMRC have opened an enquiry under TMA 1970 s 9A and are refusing these travel costs as not being wholly and exclusively for the...
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