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On a cliff edge
Key points
- The taxpayer’s description of his trade was inaccurate.
- The tribunal also determined that this inaccuracy was deliberate.
- Such a decision will have implications on penalties years open for assessment and other matters.
- The tribunal considered its decision was consistent with the comments in the Tooth case.
- Courts seem increasingly unwilling to agree that individuals did not appreciate the significance of their actions.
- The decision is not a legally binding precedent but does demonstrate a robust approach.
Mr Cliff invested in shares in racehorses and horse-racing partnerships. In his tax returns he described himself as a ‘dealer in thoroughbreds’ claiming trade loss relief. HMRC issued discovery assessments. The First-tier Tribunal held that the description was inaccurate because Mr Cliff did not...
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