The taxpayer had kept no business records and failed to notify HMRC of their liability for almost 20 years. HMRC issued discovery assessments and penalties against which the taxpayer appealed.
The First-tier Tribunal dealt first with the taxpayer’s application for anonymity. The taxpayer said that they were being financially assisted by family in a country with a poor record regarding human rights and which had been known to take action against residents who provided support to family members in countries such as the UK. The taxpayer was concerned that there would be significant risk to their family in that country if the decision were not anonymised.
The tribunal noted that the starting point for such applications was of ‘open justice’ – justice must be done in public. However derogations from this principle were allowed where a public hearing could lead to a breach of the European Convention on Human...
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