Michael Wood (deceased) v Revenue & Customs [2015] UKFTT 282 (TC) concerned the late Mr Wood, a dentist, whose tax returns for the tax years 2006-07 and 2007-08 were enquired into by HMRC over a disputed £1.3m tax bill. On 2 June 2010, Wood attempted to make a disclosure under HMRC's tax health plan (THP) settlement amnesty. His disclosure admitted underdeclarations of income for the tax years 2002-03 to 2007-08, amounting to £743,424. HMRC contended that the disclosure was not covered by the THP and instead opened a COP 9 (Code of Practice) investigation. In 2011, Wood agreed to commission a disclosure report on his tax affairs to cover the preceding 20 years. But this report was not produced so HMRC issued assessments for 1992-93 to 2005-06 totalling over £1.3m, advising that they were going back 20 years because of Wood's deliberate or negligent behaviour.
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