In Thomas v HMRC [2021] UKFTT 357 (TC) (4 October 2021) the FTT dismissed the taxpayer’s appeal against an information notice issued by HMRC under FA 2008 Sch 36 para 1.
It is worth noting at the outset that the appellant and her immediate family are no strangers to tax litigation. Connoisseurs of tax cases may well recognise the names of Spring Salmon & Seafood Ltd and Spring Capital Limited (formerly known as Spring Seafoods Ltd (SSL)) in both of which they were involved. Mrs Thomas was also one of the appellants in R and S Thomas v HMRC in 2014 in which discovery assessments and penalty determinations were upheld. This is relevant for two reasons. Firstly it was during the course of enquiries into the tax affairs of the appellant’s husband and the trust and companies with which he was associated that HMRC had become aware of certain large outgoings of the appellant which did not tally with her modest taxable income. Secondly the evidence from the 2014 case was that at least two...
