TC09619 - [2025] UKFTT 01020 (TC)

Drawing the strands together.

We have decided that HMRC have made valid discovery assessments based on section 29(5) TMA and benefit from the extended time periods of 6 and 20 years to issue the assessments.

We have also decided that the closure notices and consequential amendments are technically valid and arithmetically correct.

The appellant has not established that the amounts of additional tax assessed by HMRC, overcharge him.

HMRC have established that the appellant’s behaviour was deliberate, and we have concluded that the penalty has been properly imposed.