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Cornwall tax trial: Lessons for accountants

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15th Apr 2014
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David Winch has spent most of the last three months in the Crown Court listening to prosecution evidence concerning Simon Pearce, an unqualified accountant charged with defrauding his clients and the Revenue of £2m in tax. Below, he sets out his lessons learned from the experience, following on from his initial blog post:

So, what did I learn from this long trial which is of particular interest to accountants acting as tax agents?

He should have expected an HMRC visit 

Firstly, it should not have come as a great surprise to Pearce when HMRC officers arrived in force in May 2011 and searched his office, taking away boxes of documents including his client files and clients’ records. 

Pearce had a very long history of problems with HMRC prior to that.

There had been numerous meetings over more than 10 years with HMRC officers, in which he had been taken to task over income tax returns which he had submitted.  

In 2009 the accountant had been interviewed under caution by the police following complaints by some of his clients that he had failed to pay over their tax refunds. So the HMRC action in 2011 was far from being over-hasty or impulsive

Clients' lack of tax and accountancy knowledge 

Secondly, and perhaps unsurprisingly, in the course of giving evidence as prosecution witnesses at his trial, his former clients laid stress on their own lack of knowledge and understanding of accountancy and tax matters and their total reliance on Pearce in preparing the accounts and tax returns, which were now shown to be incorrect. 

In one exchange a witness was asked how much per week were his motoring costs. “£100 per week”, he replied. “So that’s about £5,000 per year?” said counsel. “I don’t know,” replied the witness,“I am not an accountant”.

I saw one ex-client after another enter the witness box to deny ever having provided to Pearce information which he said he had received from them in the course of client interviews. But unfortunately his brief file notes were inadequate and insufficient to demonstrate that the information had indeed come from the client.

Generally the firm dealt with ‘micro’ businesses, including a large number of CIS subcontractors.

Typically the firm would prepare an analysis for each client of business receipts provided by the client – on occasion quite literally in a bin bag – but would not trouble to analyse or examine the client’s bank statements or prepare a balance sheet.

Recognising that these records of expenditure would be likely to be incomplete, often round sum additions were made to the figures from the analyses – perhaps an extra £3,000 for motor expenses here, an extra £1,000 for tools or mobile phone charges there. 

In one case an extra £30,000 had been added to materials costs without any supporting documentation. Added to that were in some cases the more usual additions for wife’s wages, subsistence, protective clothing, use of home as office and other estimated expenses. The prosecution alleged that all these amendments were made dishonestly to generate tax refunds.

Pearce’s capital allowances computations would, I venture to suggest, have raised the eyebrows of many AccountingWEB readers – especially the routine claims of 100% FYA or AIA on the purchases of motor cars. 

So too would the claims for CGT taper relief – by multiplying the actual sales price by 25% before entering the proceeds on the tax return – in respect of tax years long after the abolition of taper relief in 2008.

Mishandled tax refunds

More serious to my mind was the mishandling of clients’ tax repayments.

Although the firm frequently received clients’ tax repayments, it did not maintain any client bank accounts. Repayment monies were paid into the ordinary business bank account and too often were swallowed up by business and personal expenditure, leaving Mr Pearce unable to forward refunds to clients promptly.

Clients were then fobbed off with excuses and explanations – by email or text message – which, when examined in the light of day, proved simply untrue. 

Often clients were told that the refunds were still with HMRC and were being held up by security checks, staff shortages, HMRC re-organisations, and so on.

Pearce then added injury to insult by billing clients for many hours spent chasing HMRC for refund monies which demonstrably had been credited to his own bank account months earlier. 

HMRC insights

It was educational for me to see the staccato ‘SA Notes’ kept by HMRC which are claimed to record (however briefly) every telephone contact HMRC have with a client or his agent. 

Only rarely did these evidence anything more than perfunctory efforts by Pearce to undertake the chasing for which he was billing.  It is worth considering, that where a single telephone call deals with several clients the SA Notes may not record that call on every client’s electronic file.

HMRC clearly take the view that the Structured Action Request online system for taxpayers and their agents must only be used, when requesting a repayment, for that repayment to be made to a bank account held by the taxpayer – even when authority has previously been given by the taxpayer for the repayment to be made to the agent. That is a view which I believe is not universally shared by tax agents.

Pearce had routinely entered his own bank account details into the online form so that the refund came to his business bank account.

The prosecution instructed a handwriting expert to examine the signatures on a number of documents including clients’ authorities for repayments to be made to Mr Pearce’s firm, authorities for tax returns to be submitted online and, in one case, a company abbreviated Balance Sheet filed at Companies House just before the penalty deadline. 

Suffice to say that ultimately Pearce was convicted of forging a number of these signatures.

So the prosecution case at trial was that Pearce had dishonestly submitted tax returns understating clients’ income, and in some cases overstating CIS tax deducted, so as to generate tax refunds which were directed to his office bank account – sometimes by abuse of the online system or by use of forged authorities – which he then failed to pay over to his clients promptly or at all, or from which he deducted unjustified fees.

It made a powerful prosecution case. But there was more.

HMRC intended in a second trial to allege that Pearce has also falsified his own tax returns and failed to register for VAT at the appropriate time.

After being convicted on 26 of the 30 counts he had faced in the first trial, Pearce changed his plea to guilty in respect of his own tax affairs – so avoiding a second trial and going straight to jail to start his sentence.

Hopefully the lessons for honest accountants about the importance of keeping good records of client meetings and explanations of estimated figures, updating tax knowledge and dealing correctly and promptly with clients’ tax refunds need no underlining from me.

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Replies (38)

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By User deleted
15th Apr 2014 10:33

Excellent summary, David

I'm sure I speak for many others in thanking you for taking the time to write this - it should certainly make the cowboys (not that I expect too many of them to be AW members :¬)  ) sit up and take notice.

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the sea otter
By memyself-eye
15th Apr 2014 10:52

This guy hardly deserved

to be called an accountant.

But why did it take HMRC TEN years to bring him to book?

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By vodkaqueen
15th Apr 2014 11:23

He didn't even deserve to be called a bookkeeper.  I was 'only' a bookkeeper for many years but even then I was able to tie up end of year stuff properly for my accountant colleagues on the more straightforward Self Assessment accounts and tax returns.  Claiming FYA for cars?  Come off it.

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By darrenwilliams
15th Apr 2014 11:37

David,

Out of interest did the clients ever receive accounts, that they signed and returned to the accountant? (thus seeing the expenses figures etc)

Just interested to hear whether the clients were potentially aware of the over claiming of expenses or did they not receive any form of accounts from the accountant?

Thanks Darren

 

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By Samantha Perkin
15th Apr 2014 11:48

He has damaged accountants reputation
I have inherited clients from him. What has been missed is that he had a large office with other staff including people who must have known. These people are now trading again.

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By kewcumber
15th Apr 2014 11:50

Darren,

I work on some micro businesses - they do all get accounts from me and I also try really hard to make sure they understand what they're signing but its an uphill struggle.  It doesn't surprise me at all that his clients didn't have a clue what their expenses were.  Their lack of knowledge may be down to him or themselves!

 

I certainly wouldn;t be adding costs for them myself - I might query whether they have given me everything if their numbers look low but taking it oupon yourself to put in different numbers than your clients have given you seems a recipe for disaster.  Which is a bit of a pointless statement given the outcome!

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David Winch
By David Winch
15th Apr 2014 11:54

Clients knowledge of their own accounts

Darren

Yes clients did typically see, and sign, a Profit & Loss Account.  How much notice they took of it is another matter.  This is illustrated by the sort of Q & A we saw a number of times in the witness box.

Q "Mr Bloggs please look at this document which is your Profit & Loss Account for the year ended 5 April 200x.  Do you see an item that says 'Wages £5,200'?"

 

A "Yes."

Q "Did you employ anyone that year?"

A "No."

Q "Where do you think that figure came from?"

A "I have no idea, I am not an accountant."

 

Only later in cross-examination on behalf of the defendant would an explanation begin to emerge.

Q "Does your wife help you in the business?"

 

A "Yes, she keeps the records, deals with business correspondence & answers the phone when I'm at work."

Q "Do you give money to your wife?"

A "Yes."

Q "Is her help worth £100 per week?"

A "She is worth much more than that!"

Draw your own conclusions!

David

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The Business Growth Secret
By anndartnall
15th Apr 2014 12:07

Clients that stupid?

I can't believe that such a high proportion of his clients were that naive as to not be aware of their true income. They just wouldn't survive as sole traders if they had so little "nouse".

Clients are supposed to get, read and sign off their SATR before it is submitted, or at least reply to the email with the SATR attached that it can be submitted in lieu of a paper signature. I hope some of them are being prosecuted as well.

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Replying to Tim Vane:
David Winch
By David Winch
15th Apr 2014 12:16

Prosecutions

anndartnall wrote:

I can't believe that such a high proportion of his clients were that naive as to not be aware of their true income. They just wouldn't survive as sole traders if they had so little "nouse".

Clients are supposed to get, read and sign off their SATR before it is submitted, or at least reply to the email with the SATR attached that it can be submitted in lieu of a paper signature. I hope some of them are being prosecuted as well.

Only Mr Pearce has been prosecuted.

A number of clients and former members of staff co-operated with HMRC by giving witness statements and, in some cases, giving evidence from the witness box during the trial.

HMRC also encouraged clients of Mr Pearce to come forward with voluntary disclosures concerning their previous years' tax affairs.

David

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Replying to Tim Vane:
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By Jekyll and Hyde
15th Apr 2014 12:30

Frustrating

anndartnall wrote:

I can't believe that such a high proportion of his clients were that naive as to not be aware of their true income. They just wouldn't survive as sole traders if they had so little "nouse".

Clients are supposed to get, read and sign off their SATR before it is submitted, or at least reply to the email with the SATR attached that it can be submitted in lieu of a paper signature. I hope some of them are being prosecuted as well.

I remember watching "The Firm" a few years ago and the bit that always stick in mind is towards the end when the FBI hooked the firm on timesheet fraud. The FBI's remark along the lines of "if accountants didn't file such accounts, the criminals wouldn't be able to launder their money". I have always thought this to be quite true and this case highlights that if the rouge accountants didn't put such expenses through then the tax payers wouldn't get away with it.

I come across too many rouges working with the smaller taxpayers, and it makes my job a lot harder. The amount of times I hear "my current accountant allows me to claim for such and such". or "do you work for the the client or HMRC" or "you are to legit" They know full when that their accountants are prepared to put through a tax fiddle at best tax evasion at worst. I hope HMRC have the backbone to approach government and ask for more funds to focus on this aspect of the smaller accountancy profession. One good way to raise revenue, rather than make it more difficult for the fully compliant taxpayer. Finally, I know of one rouge that gets around registering with HMRC for money laundering, by getting their clients to submit their own returns, etc. The sad thing about it is that a lot of the clients must think he is doing a very good job. I have taken 2 clients from him and have had to reinstate accounts ant tax returns for both clients. It is shocking that he is allowed to still trade. 

 

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Replying to arthurallan:
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By Mister O
15th Apr 2014 14:57

Too Much Rouge!?

 

Hilarious, thank you!  Who are all these blushing red accountants!? 

She wore far too much rouge last night and not quite enough clothes. That is always a sign of despair in a woman.
Oscar Wilde
 

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By GuestXXX
17th Mar 2015 17:05

.

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By Jack the Lad
15th Apr 2014 12:22

Ignorant clients ?

I used to be criticised by partners for sending long explanatory letters with the draft accounts and tax return, clearly setting out all estimates and reasoning, and requesting agreement or alternative information, prior to requesting approval to the accounts and return.  However, I still do this 50+ years on, and this Case shows the necessity and importance of that.  Inevitably my fees would be a little more than cost cutting competitors, but most clients recognised the benefits.

 Also, I rarely requested repayments to be made payable to me, unless the client had cash flow difficulties and agreed to having my fees deducted prior to paying over the balance, and then all repayments were paid into a Clients' account (isn't this a requirement of the ICAEW ?).

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Replying to jasmin505:
David Winch
By David Winch
15th Apr 2014 12:41

Client bank account

Jack the Lad wrote:

all repayments were paid into a Clients' account (isn't this a requirement of the ICAEW ?).

Yes, ICAEW requires its member firms to have a client bank account where the firm receives tax repayments on behalf of clients.  I believe other professional accountancy bodies have similar rules.

But there is no general rule that applies to all tax accountants.  It is estimated that about one in four tax accountants is not a member of any recognised professional body.

David

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By darrenwilliams
15th Apr 2014 12:30

Thanks for the reply David.

It sounds like the figures/estimates involved may be very large, probably would have been picked up a lot quicker by HMIT before online fling, when HMIT actually agreed accounts.

Samantha, interesting to hear that this is not a sole trader and a large(ish) office setup. 

Thank you.

 

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By justsotax
15th Apr 2014 12:32

conclusion...

spouse wages claimed...client doesn't understand but is happy with the tax relief....hardly shocking....and this type of practice was regular only a few years back and carried on by 'qualified' accountancy practices I venture to guess...

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Replying to lionofludesch:
David Winch
By David Winch
15th Apr 2014 12:45

The shock perhaps

justsotax wrote:

spouse wages claimed...client doesn't understand but is happy with the tax relief....hardly shocking....and this type of practice was regular only a few years back and carried on by 'qualified' accountancy practices I venture to guess...

The shock perhaps is that in the course of the prosecution case it was alleged that this (along with other matters) was indicative of dishonesty and cheating HMRC by Mr Pearce.

David

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By accountsdragon
15th Apr 2014 12:36

Stupid or afraid?

I agree with Darren.  I don't want clients just to sign off accounts and tax returns without some idea - it's their business after all.  But it is an uphill struggle.  I try to encourage them to understand their numbers, but watching their eyes glaze once I say the word 'tax' does make it difficult.

I am surprised that anndartnell is so surprised. So many self-employed people do have a good gut-feel for what they are doing, and they have plenty of nouse.  They just don't like dealing with paper and numbers.  That's what we are here for.......

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By miketombs
15th Apr 2014 12:40

Hopefully we cover the bases ....

...with CIS clients. Apart from giving them the full tax return and a computation, the fee note includes a paragraph noting that we anticipate the fees being recovered from a refund paid into our Client account, but that they remain personally responsible if for some reason that doesn't happen. In the 'authorisation to file' letter I record that the tax return is based on information they have provided, and list the major expenses included (tends to be mileage and protective clothing.)

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By Tosie
15th Apr 2014 13:36

Problem with small clients............

Over the years I have had to enter many estimated expenses, not to gain a tax refund but because I know that the client has incurred the expense but not recorded it.

I suspect that most people preparing accounts from bin bags make estimates so that part of the trial is a warning to us all.

What are we supposed to do ? We try to get clients to keep records but there are clients who have been forced into self employment who frankly are not capable of dealing with the paper work.

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Replying to leshoward:
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By User deleted
15th Apr 2014 14:13

Estimates

Tosie wrote:

What are we supposed to do ?

Quite simple - you either tell the client that unless he improves his record-keeping he's not going to get all the tax relief that he's entitled to, or make damn sure you mark the return as containing estimated figures and put a full explanation in the white box .

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Replying to leshoward:
Mark Lee headshot 2023
By Mark Lee
23rd Apr 2014 11:13

Client confirmation

Tosie wrote:

Over the years I have had to enter many estimated expenses, not to gain a tax refund but because I know that the client has incurred the expense but not recorded it.

What are we supposed to do ? We try to get clients to keep records but there are clients who have been forced into self employment who frankly are not capable of dealing with the paper work.

There has always been a need to include reasonable estimates re unvouched expenditure incurred by some owner managed businesses.

When I was in practice we always listed any such estimates included in the accounts and we required clients to confirm in writing these were reasonable or to provide alternative figures before we finalised their tax returns. 

Mark

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By justsotax
15th Apr 2014 14:00

spouse wages...

use of home (multiple of 52) adjustments etc for micro businesses...are to be fair pretty common practice amongst both chartered and QBEs....we shouldn't mistake this for the crooked way in which this guy operated to in order to line his own pockets. 

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By Tosie
15th Apr 2014 14:41

BKD

Thank you.

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David Winch
By David Winch
15th Apr 2014 14:54

@ Tosie

Don't forget if you have signed a Memorandum of Understanding with HMRC (via the Tax Agents Initiative Team) that may impact on the extent to which you can base expenses claims on estimates for CIS subcontractors.

David

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By Tosie
15th Apr 2014 17:32

thanks David

Thanks David for the reminder and ofcourse for this posting which is most helpful.

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By new2accts
15th Apr 2014 21:58

my problem with this...

Clearly this man didn't care about the law and by requesting a clients rebate into your own office account is clearly illegal, not to mention shocking behaviour considering the trust placed on him. I do worry about the clients who have stated that they were not aware of the expenses as claimed, as surely every business owner despite the lack of understanding of accountancy does understand the expenses paid, such as wages. How can you say you did not understand that £5000 was claimed for wages for example. If you did not pay it, you did not pay and should not claim a deduction for this?

This has worried me, as I do not exaggerate or make up expenses, however does this case leave the door open for other clients who have claimed illegitimate expenses to blame the accountant and an ignorance of the law? I thought that there was no defence to ignorance of the law, so surely the clients should be held to account if they were a party in the wrongdoing? ( I am not sticking up for this particular accountant, I do think however if a client signs to agree a document then it should stand that a reasonable person with capacity understood the contents)

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By North East Accountant
16th Apr 2014 08:34

To include estimates or not?

A lot of small sole traders have less than perfect books with some expenses recorded but by no means all. Would you include estimates of unrecorded expenditure based on a client interview or not? Very interested in all views, thanks.

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By Red1960
16th Apr 2014 17:02

Integrity

 

Anyone who thinks that these levels of dishonesty and incompetence are confined to the "unqualified" segment of the profession needs their head examined.

I'd not even hesitate to suggest that the sums involved in fraud and dishonesty from the "unqualified sector" represent a small fraction of those in "qualified" sector.

Scandalous to think that Mr Pearce wasn't provided with the opportunity to simply make good some small fraction of the amounts involved (say 10%) and given a stern talking to.

After all what's good for cabinet minister Maria Miller must surely be good for everyone else.

Justice must after all be seen to be impartial.

 

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By Vaughan Blake1
16th Apr 2014 17:04

Over the years I have seen many cases of the following CIS/715 subbie scenario.

Subbie works a day rate, he knows exactly how much he earns and that tax has been deducted.  He can therefore budget on spending his entire earnings safe in the knowledge that no extra tax is due.

At the year end the subby presents his accountant with CIS vouchers (I know, bring back 715 certs!), a few receipts for petrol, tools and a new van.

The accountant does the annual accounts and behold, a refund arises.  The accountant takes his fee from this (via his client account!) and pays the balance to Mr Subbie.  Mr Subbie then spends his refund on his summer holiday, location dependent on the size of the refund. Some years Majorca, others Bognor.

Mr Subbie has no idea about the accounts, AIA on his new van etc etc. He trusts his accountant and signs what he is given without actually looking at it. The tax refund is his annual 'bonus'.

Done honestly it's a pragmatic solution for everyone.  But, if the subbie only shows the CIS wages and er forgets the cash jobs and the accountant gets lazy, treats all his subby clients on a generic basis. Puts through the same estimates for travel etc as last year (plus 5%) and a figure for wife's wages just under the NI limit- (oops why didn't you tell me that she got another job three years ago and that you have been working on a site at the end of your road since the Newcastle contract finished) then it develops into the situation we have here.

Laziness, criminal ignorance and arrogant complacency as much as actual outright dishonesty here. I don't think that making a few small reasonable estimates based on the specific facts of the case and reviewed annually, will see any of us sharing a cell with Mr Pearce!

Subby quote of the century was, 'all my cash jobs are done on a Saturday which because it's my day off ain't taxable'

 

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By DMGbus
17th Apr 2014 13:42

Omitting estimates = false accounting

If I produce a set of accounts that omit legitimate business costs (because I've decided to omit those without invoices) then those accounts portray a false picture of overstated profitability.      Absolutely wrong, especially if such accounts' net profit figure is used to support a mortgage application.

Therefore I always advocate inclusion of ALL business expenditure vouched or not, if no immediate supporting documentation then appropriate computations should be used to support the estimate used and be ever so careful not to overstate (or understate) said expenses.   Regarding vehicle fuel there will be MoT test certificates or servicing records to assist in computing appropriate value for petrol or diesel.

Tax relief is a separate issue.   The first firm foundation of a tax return is accounts that show the whole of both the income and the expenditure.  Beyond this point some accountants (*) might feel it "necessary"  to disallow estimated expenditure for SA103 purposes, that is their only legitimate way of disallowing said expenditure.

(*) "Some accountants" may well fairly be regarded by their clients as "working for the Revenue" as this is a good example of bad accounting - the omission of legitimate (but maybe too difficult or troublesome for them to quantify) expenditure from a set of accounts.

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David Winch
By David Winch
17th Apr 2014 15:27

Estimates v HMRC TAIT MoU

But might there be a problem (in the case of a subcontractor in the construction industry) where the accountant has signed a Memorandum of Understanding with HMRC (Tax Agent Initiative Team) and including estimated expenses would result in expenses exceeding 20% of turnover (because records will not be available to support that)?

David

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By justsotax
17th Apr 2014 15:28

I think the article (and the prosecution case)

loses a little integrity when the heading 'client's lack of accountancy and tax knowledge' is matched with the client unable to multiply £100 by 52 weeks...the last time I checked the ability to multiply was not exclusive to 'accountants'.  It seems the clients wanted to distance themselves from the accountant by proving just how stupid they are.  (never mind the conversation suggesting they pay their spouse to reduce their tax bill, which they then conveniently forgot....cynical....yup!) 

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David Winch
By David Winch
17th Apr 2014 16:23

@justsotax

I think the point you are making is exactly the one I was making in the article.  The clients were distancing themselves from the accounts and tax returns & blaming everything on Mr Pearce.

Of course the prosecution were only interested in demonstrating to the jury that Mr Pearce was guilty of the offences with which he had been charged.  That is the purpose of the prosecution in a criminal trial.

David

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By jndavs
24th Apr 2014 16:30

Estimates

I have some guard ducks....

 

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By ccassociates
09th May 2014 10:32

Fiddler at the desk

Too many self employed and particularly those in CIS see their accountant as the person whose job it is to fiddle their tax, they honestly believe that is our purpose. This can be evidenced further by those who are in full time employment and always have been who also believe that is the purpose of an accountant.

Add that to the fact that some of these unfortunate yet hard working subbies are not the sharpest tool in the box and I can believe that there are some who cannot multiply 100 by 52. I once knew a marvelous carpenter who could not read or write and had difficulty adding up, but put him on a dartboard and he would calculate your "out" in seconds

Men like Pearce take advantage of this culture in order to line their own pockets, I have witnessed the same behavior from qualified FCA's and ACCA's working on a percentage of the refund as their fee.

I see part of my job as educating the client as to what is legitimate and the consequences of fiddling and on the rare occasion that I claim un-vouched expenditure I make sure the client understands that I expect him to keep all his receipts next time, those who choose not to accept or to question my methods are not retained as clients, as experience shows that the first thing the client tells HMRC in an investigation is. "my accountant told me to do that "

Strangely enough I am working on a sub-contractors accounts right now, and I see that he has not taken my advice to stop buying [***] , chewing gum, coke, etc with his fuel on his debit card as the time I spend removing them increases his fee, ho hum! 

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By Richard Cliff
11th Aug 2023 17:53

Thank you David for this insight into the world of a fraudulent accountant. Before setting out on 1 September 2023 I would like you to inform me of anything else I need to set up. I am collecting documents to provide back up for client's identities and their location. Other than having fully documented working papers, accounts, tax returns, payroll and VAT is there anything else I will need?

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By Richard Cliff
11th Aug 2023 17:53

Thank you David for this insight into the world of a fraudulent accountant. Before setting out on 1 September 2023 I would like you to inform me of anything else I need to set up. I am collecting documents to provide back up for client's identities and their location. Other than having fully documented working papers, accounts, tax returns, payroll and VAT is there anything else I will need?

Thanks (0)
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By Richard Cliff
11th Aug 2023 17:53

Thank you David for this insight into the world of a fraudulent accountant. Before setting out on 1 September 2023 I would like you to inform me of anything else I need to set up. I am collecting documents to provide back up for client's identities and their location. Other than having fully documented working papers, accounts, tax returns, payroll and VAT is there anything else I will need?

Thanks (0)