UT/2022/000131 - [2025] UKUT 00063 (TCC)

Case Number: UT/2022/000131

By remote video hearing

INCOME TAX – discovery assessment and penalties for deliberate behaviour – adequacy of reasons given by First-tier Tribunal – consideration of decision of Court of Appeal in English v Emery Reimbold & Strick – review of FTT’s reasons in the context of HMRC statement of case and skeleton argument - appeal dismissed

Judgment date: 19 February 2025

Before

JUDGE NICHOLAS ALEKSANDER

JUDGE KEVIN POOLE

Between

HENRY RAFFERTY

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Joseph Quinn, accountant

For the Respondents: Rebecca Sheldon, counsel, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs

DECISION