In Rebecca and Sarah Thomas v HMRC [2014] UKFTT 980 (21 October 2014) the FTT found that discovery assessments were valid and that the taxpayers had been negligent.
In their tax returns Rebecca and Sarah Thomas had claimed income tax share loss relief of £100 000 on the basis that the company had been struck off as well as a deduction for tax already deducted (or which should have been deducted) from interest received on a loan made to the company.
HMRC had issued discovery assessments disallowing the share loss relief claims and treating the interest as being gross rather than net. It also imposed penalties for negligently making incorrect returns.
The FTT firstly found that the discovery assessments had been validly made as the information provided in the returns would not have enabled the ‘hypothetical officer’ to identify an insufficiency of tax...
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In Rebecca and Sarah Thomas v HMRC [2014] UKFTT 980 (21 October 2014) the FTT found that discovery assessments were valid and that the taxpayers had been negligent.
In their tax returns Rebecca and Sarah Thomas had claimed income tax share loss relief of £100 000 on the basis that the company had been struck off as well as a deduction for tax already deducted (or which should have been deducted) from interest received on a loan made to the company.
HMRC had issued discovery assessments disallowing the share loss relief claims and treating the interest as being gross rather than net. It also imposed penalties for negligently making incorrect returns.
The FTT firstly found that the discovery assessments had been validly made as the information provided in the returns would not have enabled the ‘hypothetical officer’ to identify an insufficiency of tax...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
