The Weekly Law Reports
[2021] 1 WLR 2811
Supreme Court
*Revenue and Customs Commissioners v Tooth
[2021] UKSC 17
2021 March 2, 3; May 14
Lord Reed PSC, Lord Briggs, Lord Sales, Lord Leggatt, Lord Burrows JJSC
Revenue— Income tax— Assessment— Taxpayer filing online self-assessment tax return— Limitations of online form preventing taxpayer from entering employment loss— Taxpayer deliberately entering loss as partnership loss and explaining situation in additional information box— Revenue officers regarding tax return as understating tax liability but not opening enquiry— Different revenue officer issuing discovery assessment five years later on basis return containing deliberate inaccuracy— Whether return containing “deliberate inaccuracy”— Whether insufficiency in return “brought about … deliberately” by taxpayer— Whether “discovery” made by later revenue officer—
Taxes Management Act 1970 (c 9), ss 29, 118(7)