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Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)
Published on: 14 May 2021
Published by: LexisPSL
  • Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)
  • What are the practical implications of this case?
  • What was the background?
  • What did the court decide?
  • Deliberate inaccuracy
  • Qualifying discovery—staleness
  • Case details

Article summary

Tax analysis: The Supreme Court has found unanimously in favour of the taxpayer (Raymond Tooth) that he had not made a deliberate inaccuracy in his return and therefore the discovery assessment raised against him was invalid. The Court also concluded that there is no concept of staleness in the statutory scheme for raising discovery assessments. or take a trial to read the full analysis.

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