Decision Number: | TC 08253 |
Appellant: | David Cation |
Respondent: | The Commissioners for Her Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
Dr Heidi POON |
Date Of Decision: | 04/09/2021 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | INCOME TAX and PENALTIES - self-assessment return - enquiry and closure notice - s 34 of ITTOIA 2005 - deductibility of payments to father - lack of business records as required by s 12B TMA - taxpayer-™s object in incurring expenditure - whether -˜wholly and exclusively-™ for the purpose of trade - Schedule 41 FA 2008 and Schedule 24 FA 2007 - failure to notify liability and inaccuracy - interaction of penalties - whether deliberate - appeal dismissed |