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A taxpayer had no right to a separate hearing to determine whether conditions of the Tax Management Act, s 29 had been met

Published:

Re: Hargreaves v Commissioner for Her Majesty’s Revenue and Customs [2016] EWCA Civ 174

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.