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More HMRC incompetence

The familiar one of failing to open an enquiry promptly enough

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Allowing 2 out of 3 SDLT scheme clients off the hook for £10,000s:

https://www.bailii.org/uk/cases/UKFTT/TC/2020/TC07665.html

So much for HMRC's claims that tax avoidance doesn't pay!

That said, those 2 taxpayers were a bit lucky to have this particular judge - his comments in para 206 are a bit naive to put it mildly and his view in para 204 looks plain wrong. So HMRC are bound to appeal and the taxpayers will then be exposed to a cost risk, so possibly tax avoidance doesn't pay after all in this case.

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By richard thomas
21st May 2020 15:21

Ashley's approach to the disclosure note is somewhat different to that I took in the case referred to at §98 of his decision. See §§51-72 and §§81-86 in Timothy Gray.

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By Justin Bryant
22nd May 2020 10:15

Indeed. No-one can accuse you of any naivety re para 86 of Timothy Gray (the judge in the above case seems to have had a fair bit of wool pulled over his eyes compared to you)!

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By richard thomas
22nd May 2020 17:28

You don't get to be a tax inspector for 37 years without developing some nose for a dodgy situation!

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