“There are no workings that show which receipts in the bank statement are being deemed as unrecorded income. The calculations provided by the Respondent are not clear. There is no guarantee that an error has not occurred due to the method used to arrive at the unrecorded income. When undertaking investigative work (which is what the Respondent undertook) it is standard practice that figures flow back to source documents. The Appellant expected to see an excel sheet analysing the bank statements line by line which would then show a complete analysis of receipts and payments with sub totals for various categories.”
“This skeleton argument only refers to documents in the Hearing Bundle that have been lodged by the Respondent. The Respondent has refused to include documents provided by the Appellant as they allege that the documents were sent late. The matter of whether the documents should be allowed will be heard at the start of the Tribunal Hearing. It is not clear how and when the Hearing Bundle will be updated if the documents from the Appellant are allowed. The Appellant is therefore unable to refer to its documents in this Skeleton Argument.”
“HMRC respectfully request that the Tribunal dismiss the appeal and amend The Assessments and The Closure Notices in line with the figures shown on the document titled Summary.”
“HMRC requested that this be reduced to£55,008 , based on estimated revised profit of£55,000 and foreign bank interest of£8 .”
“HMRC requested that the assessment be amended to increase the amount assessed to£170,006 . This was based on identified taxable deposits in Mr Patel's bank accounts of£176,931 . Estimated expenses of£5,500 were deducted, based on analysis undertaken for other years. This gave an estimated revised profit of£171,431 , which was rounded down to£170,000 . Mr Patel also received foreign bank interest of£6 .”
“the FTT erred in law by concluding that HMRC had in fact “discovered” a loss of tax in circumstances where HMRC made no real attempt to ascertain Mr Patel’s true liability for those years”
“the FTT erred in law in failing to make any findings as to the validity of the enquiries or closure notices which charged Mr Patel to tax.”
“The procedural questions of whether The Assessments and The Closure Notices are valid – and whether the Respondents made a discovery for the purposes of s29 TMA 1970 – also need to be addressed by the Tribunal.”
“The FTT erred in law in its application of the burden of proof where HMRC were seeking to increase the amount of the original assessments and/or closure notices. As a consequence, the FTT failed to make a finding that the increased assessments/closure notices were proved to the proper standard.”
“The FTT erred in law in its application of the burden of proof where HMRC were seeking to change the amount of the original assessments and/or closure notices. As a consequence, the FTT failed to make a finding that the increased assessments/closure notices were proved to the proper standard.”
“The FTT erred in law accepting HMRC’s assertions as to what was contained in certain bank statements, without requiring HMRC to adduce those statements, and by adopting an inconsistent approach to its evaluation of the evidence.”
“The difficulty with this Ground is that it does not specify the years which are said to have been wrongly decided on the basis of incomplete evidence. If Mr Brodsky is seeking by this Ground to submit that the increased assessments were based on HMRC’s schedules, while Mr Patel’s schedules for the same year were unfairly rejected, that is essentially encompassed within Ground 3, as being a challenge to the way the FTT made its findings about the increased assessments. If it goes wider, permission to appeal is refused because the Ground is insufficiently pleaded and thus does not identify an arguable error of law.”
“The FTT erred in law by failing to carry out any legal analysis of Mr Patel’s employment status. Further, the FTT’s factual analysis of Mr Patel’s employment status was flawed and reached conclusions that no reasonable Tribunal could reach.”
“The FTT erred in law in its application of the ‘presumption of continuity’, including by failing to give any or any adequate reasoning for why some years were chosen as the ‘base year’ for continuity into other years, and by elevating that presumption to the status of a legal principle.”
“The FTT erred in law because it failed to make findings about the tax payable by Mr Patel and/or it failed to set out conclusions which could be understood by him or by the reasonable reader of the Decision. In particular, the Decision confused the tax assessed with the income chargeable. At [93] the Decision cites TMA s 50 as allowing the FTT to increase or reduce a (tax) assessment. The FTT was thus relying on TMA s 50(6) and (7), and not on subsection (8), which refers to changes to ‘the amount assessed’. However, as now clarified by HMRC, their schedule and summaries related to profits and not to tax, and it was these figures which the FTT adopted and accepted. The FTT thus relied on the wrong statutory provision and this was a further error of law.”
“The FTT erred in law by not holding a hearing in relation to significant parts of the dispute between the parties, instead directing submissions on the papers. HMRC provided 45 pages of detailed analysis and it was not in the interests of justice for Mr Patel, a litigant in person, to be required to respond in writing to those submissions.”
“It was an error of law for the FTT to make its Decision without first ensuring that Mr Patel had received and had time to consider the bank statement evidence on which HMRC had based their calculations.”