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J White v HMRC

In J White v HMRC [2018] UKUT 257 (7 August 2018) the UT accepted HMRC’s decision to treat a single letter as both opening and closing an enquiry.

Mr White was in the business of skip hire. In October 2012 he wrote to HMRC to correct his self-assessment return for 2008/09 2009/10 and 2010/11. The corrections related to relief for what were described as irrecoverable debts in connection with loans that Mr White had made to a company M White Limited that was owned by his father. HMRC rejected the corrections on the basis that the irrecoverable debts were not allowable for income tax relief because the loans were capital investments; and the loans were not wholly and exclusively laid out for the purposes of trade.

The UT observed that Mr White considered the communications from HMRC refusing to accept the correction to his...

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