A taxpayer had no right to a separate hearing to determine whether conditions of the Tax Management Act, s 29 had been met
Hargreaves v Commissioner for Her Majesty’s Revenue and Customs  EWCA Civ 174
- Related Member(s):
- Clare Montgomery QC
- Related Practice Area(s):
- Tax Law
- Court of Appeal (Civil Division)
Whether HMRC was required to establish, at a separate preliminary hearing prior to the hearing of the appellant’s appeal against a “discovery” assessment pursuant to the Taxes Management Act 1970, s 29, the matters which were required to show that the discovery assessment was validly made. Held: A taxpayer had no right to a separate hearing to determine whether the discovery assessment conditions had been met. Clare Montgomery QC was involved in this case.