Information was reasonably required

The taxpayer appealed against an information notice issued by HMRC under FA 2008 Sch 36 para 1.

During enquiries into the tax affairs of the taxpayer’s husband HMRC became aware that the taxpayer had taken out a £1m mortgage and loaned the funds to a company (TML). She had also made loans of £250 000 to TML and £650 000 to SSL. TML had assigned two debts due it to her and she had reassigned the total debt to SSL on the same day.

HMRC asked about the source of the funds in the taxpayer’s bank account enabling her to make the loans. It required details of any material deposits above £20 000 for the 12 months before each payment was made. If any gifts or funds had been provided by other parties Mrs Thomas was asked to provide particulars of dates and reasons. Other questions related...