Three-year delay of discovery assessment resulted in discovery becoming stale (Mehrban v HMRC)

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Article summary

Tax analysis: In Mehrban v HMRC, the First-tier Tax Tribunal (FTT) found that a three-year delay between HMRC discovering an insufficiency of tax and the issuing of a discovery assessment meant that the discovery had become stale. It did not matter that the delay had partly been caused by HMRC asking for further information which the taxpayer had not provided.