G K Patel v HMRC

Cathya Djanogly

In G K Patel v HMRC [2016] UKFTT 760 (14 November 2016) the FTT applied both Data Select [2012] UKUT 187 and BPP [2016] STC 841 when dismissing an application for a late appeal.

Mr Patel ran a ‘mini market’ in Brixton trading as Kirshen News. This operated as a grocers and off-licence and also sold confectionery tobacco and newspapers. He had purchased the business in March 2003 and commenced trading in April 2003. HMRC had opened an enquiry in December 2010 and had found no clear records of sales. It established that Mr Patel had paid a £45 000 deposit on a mortgage which he could not have funded from private savings. HMRC therefore adjusted Mr Patel’s recorded income on the basis of information obtained from one of his suppliers and issued both a closure notice and a penalty.

Alternative dispute resolution (ADR) was offered...

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