TC09619 - [2025] UKFTT 01020 (TC)

Fecha: 06-Ago-2025

THE EVIDENCE AND THE FACTS

THE EVIDENCE AND THE FACTS

We were provided with a substantial bundle of documents which included authorities. The appellant gave oral evidence on which he was cross examined. Oral evidence on behalf of HMRC was given by Officer John Caulfield (“JC”). From this evidence we find as follows:

Heading
INTRODUCTION
THE EVIDENCE AND THE FACTS
Background
Submissions
Our view
The discovery assessments
The overcharge
The closure notices
The penalty
Conclusion
Conclusions