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A shop owned by K sold jewellery on behalf of third parties – referred to as appro sales – as well as selling its own products.
The appro items did not form part of the store’s regular stock. Once such an item had been sold the proceeds were passed to the third party minus a commission.
The appro goods included some jewellery belong to K’s mothers. The proceeds from the pieces were paid into a joint account in Guernsey. They were not included in the records of the shop because K believed he was selling the pieces on behalf of his mum.
In 2008 HMRC contacted K about the joint account in Guernsey and raised assessments on what they believed to be undeclared income. The taxpayer appealed.
The First-tier Tribunal noted K had been “evasive and uncooperative” when first questioned by the Revenue but had subsequently invited...
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