HMRC v Charlton Corfield & Corfield [2012] UKUT 770 (TCC) (20 December 2012)
"Capital Gains Tax – whether discovery assessments valid – s 29, Taxes Management Act 1970 - meaning of “discovery” – inference of information under s 29(6)(d)(i) – inclusion of DOTAS scheme reference number in return - whether an officer could not have been reasonably expected to be aware of an insufficiency of tax (s 29(5)) – nature of the hypothetical officer"
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