Ground (d)
Ground (d)
The FTT considered the Applicant’s explanation that his winnings came from gambling. HMRC had taken account of this explanation throughout its enquiry and significantly reduced the assessments accepting that some credits and income were accounted for from this source. Thereafter the FTT was entitled to reject the explanation that all of the unexplained credits came from this source and gave sufficient reasons for doing so. This was a finding open to the FTT on the evidence for the reasons it gave (particularly those at [74]-[79]).
- Heading
- JUDGE RUPERT JONES Introduction
- The application for permission to appeal to the UT
- UT’s jurisdiction in relation to appeals from the FTT
- The grounds of appeal
- Discussion, Analysis and Decision
- Ground (a)-(c)
- Ground (d)
- Ground (e)-(g)
- Ground (h)
- Ground (i) and (j)
- Grounds (k) and (l)
- The CGT appeal
- Further grounds from the speaking note / oral submissions
- Conclusion to the speaking note and fresh evidence application and grounds
- Problems with the bundle rendering the hearing procedurally unfair
- Conclusions
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