Taxpayer’s evidence was unreliable

The taxpayer ran a fish and chip shop. HMRC opened an enquiry which resulted in it issuing discovery assessments and penalties for the years 2001-02 to 2015-16 against which the taxpayer appealed.

There were various issues for the First-tier Tribunal to consider in relation to the assessments. These included whether they were valid; whether the assessment for 2005-06 had been made in time; whether the taxpayer ran the shop in a partnership with his brother S to the effect that S was entitled to 90% of the profits; whether the trading profits should be reduced because that business was run as a partnership with S; whether legal costs were deductible; whether rental profits should be reduced on the basis that he was in a joint venture with another person; and whether the assessments should be increased for three of the years to take into account a newly...