Hargreaves v Revenue And Customs [2014] UKUT 395 (TCC) (08 September 2014)
Procedure – preliminary issue – Capital Gains Tax – appeal against
discovery assessment on basis both that HMRC not competent to make
assessment and that taxpayer not in fact resident during year of assessment
– whether competence of HMRC to make discovery assessment should be
heard as a preliminary issue – s. 29 Taxes Management Act 1970
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