Jerome Anderson v The Commissioners for HM Revenue and Customs:[2018] UKUT 0159 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Morgan and Judge Berner on 17 May 2018.
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INCOME TAX 鈥� discovery assessment 鈥� s 29 TMA 鈥� meaning of 鈥渄iscover鈥� 鈥� subjective and objective tests 鈥� whether Revenue officer believed that there had been an insufficiency of tax 鈥� whether officer merely had grounds for suspicion 鈥� whether it was open to officer to believe that there had been an insufficiency of tax 鈥� whether losses claimed to have arisen in a soccer academy trade were available for sideways loss relief 鈥� ss 64 and 72 ITA 鈥� whether taxpayer carried on a trade 鈥� whether on a commercial basis and with a view to or realistic expectation of profit 鈥� ss 66 and 74 ITA 鈥� whether tax-generated losses 鈥搒 74B ITA.