Readers' forum: After the event

A client has been in business as a sole trader since June 2015 with an annual income of some £165 000. Having been employed before the start of her business she has never filed or been asked to file tax returns. Nor did she have the opportunity to register with HMRC for self-assessment before she was served with discovery assessments under TMA 1970 s 29 which showed substantial liabilities in respect of both 2015-16 and 2016-17. We find this approach somewhat unusual since HMRC chose not to issue TMA 1970 s 8 notices to deliver returns for years that are well within time. These could have been followed by determinations issued under s 28C had HMRC considered these necessary. Given that our client believes the assessments to be excessive we are considering the submission of self-assessment returns for the two years covered by...