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29 June 2009
Issue: 4212 / Categories: Tax cases
Deadman and anor (TC44)

The taxpayers were husband and wife and were partners in a partnership. HMRC opened an enquiry into the husband’s self assessment tax return and the partnership return for 2005/06.

They said information showed that the husband had undeclared offshore bank accounts and that he had not declared the relevant interest.

Notices under TMA 1970 s19A were issued requesting statements in respect of the offshore accounts as well as his other personal bank accounts. The husband and partnership appealed against the s 19A notices.

HMRC subsequently issued further assessments against the husband and wife charging them an additional share of partnership profits and charging the husband additional bank interest. The taxpayers appealed.

Meanwhile separately from the enquiry the taxpayers’ accountant wrote to HMRC’s offshore disclosure unit stating that the couple had only just become aware of the offshore disclosure arrangements and requesting extra time...

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