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The taxpayer appealed against a number of HMRC assessments made under TMA 1970 s 29 for the tax years 1990/91 to 2002/03 and 2003/04 and 2004/05.
The taxpayer had been a self-employed landscape gardener for several years. It was not until 2009 when statements for a bank account in his name came to light during an enquiry into the tax position of a third party that he came to HMRC’s attention.
This caused the department to carry out an investigation into the appellant in respect of the earlier years which would go back beyond the normal time limit.
They issued 13 years’ worth of assessments made to the best of the officer’s judgment as little could be ascertained about the taxpayer’s lifestyle.
The taxpayer appealed.
The First-tier...
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