TC09550 - [2025] UKFTT 00702 (TC)

This is Mr Lucas’s appeal against Discovery Assessments for the tax years 2016/17 to 2020/21 inclusive in the amounts respectively of: £689.20, £829.20, £809.00, £738.20 and £511.00, a total of £3,576.60. All the assessments were made on 21 February 2023. The assessments for 2016/17 and 2017/18 were therefore made outside the normal four-year time limit in section 34 Taxes Management Act 1970 (TMA) and HMRC must satisfy the provisions of section 36 TMA in relation to those years by showing the Appellant or his agent acted carelessly or deliberately.

The assessments were made to recover a loss of tax arising from excessive claims for expenses made in the relevant years.

We have considered the authorities referred to by the parties but, in the interests of keeping this decision as concise as possible we have not found it necessary to refer to them specifically.

References to sections and subsections are to section 29 TMA unless otherwise specified.