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INCOME TAX - Part 4 Finance Act 2004 - pension fund - whether unauthorised member payment - assessment of unauthorised payments charge and unauthorised payments surcharge - discovery assessment - whether conditions in s29 TMA 1970 were satisfied - appeal allowed
For the Respondents: �� Alex Turnbull, litigator of HM Revenue and Customs� Solicitor�s Office
Mrs Curtis has appealed against the Assessment on the ground that there was no unauthorised member payment. She has also appealed against a decision of HMRC not to discharge the unauthorised payments surcharge.
(1) Was the loan of �20,000 made to Mrs Curtis by Blu Funding an unauthorised member payment?
(2) Was HMRC entitled to make the Assessment pursuant to section 29(1) Taxes Management Act 1970 (�TMA 1970�)?
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