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In Timothy and Alison Johnson v HMRC [2022] TC08483, the First Tier Tribunal (FTT) found discovery assessments were validly raised as the appellant’s tax agent had been careless in omitting compensation payments from their tax returns.

The FTT dismissed the appeal finding that:

Useful guides on this topic

Discovery Assessments
When can HMRC issue an assessment outside of the normal statutory time limits? What conditions must be met? What are your rights of appeal and defences?

Client guide: Reasonable care and tax penalties
What triggers a tax penalty? What standard of care is expected from a taxpayer? What is reasonable care? When is an error careless?

How to appeal an HMRC decision
Disagree with an HMRC decision? How to appeal, what type of decision can you appeal and what are your different options when you disagree with HMRC? What are the key steps in making an appeal?

External links

Timothy and Alison Johnson v HMRC [2022] TC08483


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