Inadequate and inconsistent evidence provided by the taxpayer

The taxpayer appealed against income tax assessments issued by HMRC under TMA 1970 s 29 s 34 and s 36 for the years 2001-02 to 2016-17. He accepted that he failed to notify a liability to tax in those years but disputed the sums assessed.

In January 2017 HMRC issued a notice under FA 2008 Sch 36 because the taxpayer had not responded to an earlier request for information including his personal bank statements.

At a meeting in March the taxpayer said he had registered for self assessment although it transpired this step had not been taken. On receipt of the bank statements HMRC identified various sums relating to rent payments and property transactions so the officer asked for the related profit and loss accounts. The taxpayer emailed spreadsheets covering the years 2011 to 2015 along with a letter setting...