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Discovery assessments were valid

12 May 2025
Issue: 4984 / Categories: Tax cases
A Brown ( TC9493)

The taxpayer had been within self assessment but left it in 2011. His spouse received child benefit from 2007. For the years under appeal – 2018-19 and 2019-20 – the taxpayer’s income exceeded the £50 000 threshold so he became liable to the high income child benefit charge. In January 2021 HMRC issued a nudge letter and in June 2021 it opened an enquiry. In April 2022 HMRC wrote to the taxpayer notifying him that it would issue discovery assessments for those years. It also imposed penalties but later cancelled them.

The taxpayer appealed.

The First-tier Tribunal accepted that HMRC had made a valid discovery. The taxpayer accepted the figures assessed but said he had been treated unfairly and that the impact of the assessments had been detrimental to his health.

It was clear to the judge that the taxpayer did not understand the assessments or why...

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