01 August 2016
UT Decision: The personal representative of Michael Wood (Deceased) v HMRC
INCOME TAX – discovery assessments made against taxpayer relying on extended time limits on grounds of deliberate conduct – death of taxpayer – whether assessments should be discharged on grounds personal representative cannot receive a fair trial-ss 29 and 36 TMA 1970- Art 6 Human Rights Convention-appeal dismissed.
David Yates, Counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents.
To see the approved Decision click here.