I have just taken on board a new client, Mr X.
Apparently in 1995 he gifted his commercial property (a butcher) to his son, Mr Y. His son, Mr Y has since then shown all the rental income on his return.
However, it has become apparent that Mr X and Mr Y have never made a holdover claim on the transaction.
Do you think the Inspector would accept a late holdover relief claim 9 years late (allowing for the 5 years to make the claim)?
Can HMRC make a discovery assessment at this late stage?