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In jeopardy

28 May 2008
Categories: Tax cases
Smith (SpC 680)

The appellant was the chairman and chief executive of a company for ten years to 2001. The inspector opened an enquiry into the company accounts for the years 1991 to 1995 and as part of that enquiry requested production of various private documents belonging to the appellant. As a result the inspector discovered unexplained deposits in the appellant's bank account and personal expenditure on his employer's credit card.

The inspector raised discovery assessments under TMA 1970 s 29 for the years 1992-93 to 1996-97 and 1998-99. As the assessments for 1992-93 and 1993-94 were out of time the inspector said that the 20-year time limit under s 36(1) should apply on the grounds that the appellant had been negligent in failing to return benefits in kind and profits arising from unexplained deposits. A jeopardy assessment for 1997-98 was issued under s 9C.

The taxpayer appealed.

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