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Alistair Norman v HMRC

In Alistair Norman v HMRC [2015] UKFTT 0303 (22 June 2015) the FTT found that a discovery assessment was valid and that the taxpayer was entitled to relief so as not to be taxed twice in relation to the same transaction.

On joining a company as employee Mr Norman had been offered stock options. He had left the company two years later and had exercised part of the stock options and immediately sold the shares. He had used the Citigroup transaction record to complete the CGT pages of his return declaring a chargeable gain on the sale of the shares; and had used the P45 provided by his employer to complete the employment pages of his return. HMRC had issued a discovery assessment considering that income tax was due on the stock options.

The FTT first confirmed that HMRC had made a discovery for the purpose...

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