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Curtain-maker
The taxpayer was director and shareholder of a curtain-making company. In 1992, his company received a qualified audit report because of unexplained stock losses of £82,000. The Inspector thought that the taxpayer sold off-cuts and new rolls of fabric owned by the company, for his own account.
The taxpayer appealed against assessments for 1992-93 to 1998-99.
Curtain-maker
The taxpayer was director and shareholder of a curtain-making company. In 1992, his company received a qualified audit report because of unexplained stock losses of £82,000. The Inspector thought that the taxpayer sold off-cuts and new rolls of fabric owned by the company, for his own account.
The taxpayer appealed against assessments for 1992-93 to 1998-99.
The taxpayer did not appear for the Special Commissioner's hearing, his whereabouts were unknown, and he was believed to have left the country. The taxpayer's accountants investigated his and his wife's bank accounts for the years end 5 April1992 to 1996, finding unexplained deposits. The Inspector made assessments for those years using the information, and for the years 1996 to 1998, he used his own analysis of the bank accounts. The assessments were made under Schedule D Case I, but Schedule E assessments were also raised in respect of benefits.
The Revenue said that the taxpayer had been negligent and thus it could make the assessments for the out of time years. The Special Commissioner agreed that the taxpayer had been negligent and confirmed the assessments.
The taxpayer's appeal was dismissed.
Smith (SpC 498)
