United Kingdom Upper Tribunal (Tax and Chancery Chamber)

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You are here: BAILII >> Databases >> United Kingdom Upper Tribunal (Tax and Chancery Chamber) >> Pattullo v Revenue and Customs [2016] UKUT 270 (TCC) (14 June 2016)
URL: http://www.bailii.org/uk/cases/UKUT/TCC/2016/270.html
Cite as: [2016] STC 2043, [2016] BTC 510, [2016] UKUT 270 (TCC)

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Pattullo v Revenue and Customs [2016] UKUT 270 (TCC) (14 June 2016)

CAPITAL GAINS TAX – Discovery assessment; tax avoidance scheme involving capital redemption policies; when HMRC officer discovered that assessment was insufficient; whether there can be a series of discoveries; whether the discovery became stale; TMA 1970 s 29(1); whether officer could not have been reasonably expected to be aware of the insufficiency at earlier date; attributes of the hypothetical officer; what constitutes such awareness; tests to be applied; TMA 1970 s 29(5); Appeal dismissed

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