THE MAGNET PARTNERSHIP v Revenue & Customs (INCOME TAX - discovery assessments - deliberate behaviour by agent)

INCOME TAX - discovery assessments - deliberate behaviour by agent - extended time limits - whether validly made - yes - amendments confirmed

For the Respondents: �� Simon Bracegirdle, litigator of HM Revenue and Customs� Solicitor�s Office

             �If something sounds too good to be true, it probably is� is a well-known idiom. The appellant�s (�Magnet�s�) profits returned in the tax returns for the years 2004/05 to 2014/15 were precisely zero regardless of turnover.

             This appeal relates to discovery amendments to Magnet�s partnership tax returns for the tax years 2004/05 to 2014/15.

             This appeal was originally conjoined with appeals for the Haritou Partnership (�Haritou�) (TC/2020/02080) and the Alan Fada Partnership (�Fada�) (TC/2020/02079) which were allowed of consent by the Tribunal�s Direction dated 3 February 2022.