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Addo (TC6700)
HMRC issued discovery assessments for 2009-10 and 2010-11 under TMA 1970 s 29 relating to the taxpayer’s participation in a contractor loan scheme. She appealed against these. However the matter before the First-tier Tribunal concerned documents held as evidence by HMRC that the taxpayer wished disclosed to her. The documents were referred to in a witness statement of F an HMRC officer and included:
- copies of notes of consultations between specialist investigations teams and the specialist technical team that handled contractor loan schemes;
- notes of discussions with the anti-avoidance group;
- the independent review panel report;
- the handling strategy for opening enquiries and raising discovery assessments; and
- notes of discussions between an HMRC officer and the department’s discovery specialists.
The taxpayer argued that she should be entitled to...
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