Reasonable Expectations

SECTION 29 TAXES Management Act 1970 has recently come under the spotlight. First in Langham v Veltema [2004] STC 544 the Court of Appeal upheld the right of the Inland Revenue to raise a discovery assessment on a taxpayer who had previously relied upon a professional valuation where the valuation was subsequently found to have been inadequate. Secondly as reported in Update Taxation 24 June 2004 at page 323 the (as yet) undecided case of Jones v Garnett otherwise known as the Arctic Systems or section 660A appeal recently heard by the Special Commissioners opened with the announcement that the Revenue had decided at the last minute to abandon the assessments raised under section 29.

Section 29 discovery assessments can only be raised in limited circumstances. The first situation is where there...