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INCOME TAX � Enquiry into self-assessment return � Appeal against closure notice � Deposits in bank account claimed by the Appellant in oral evidence to be loans or gifts � Absence of documentary evidence supporting claim � Closure notice treating the deposits as earnings � Whether HMRC acted perversely or in bad faith � No � Appeal dismissed
Sitting in public in Sutton on 29 September 2011 and in Ashford on 16 March 2012
The Appellant in person on 29 September 2011, no appearance by or on behalf of the Appellant on 16 March 2012
The Appellant appeals against a closure notice dated 6 August 2010, amending his 2006/07 self-assessment tax return under s.28A(1) and (2) of the Taxes Management Act 1970 (the �TMA�).� The Appellant�s tax return had indicated that he was not due to pay any tax.� The closure notice concluded that he was due to pay �9,316.08 tax.� A statutory review was concluded by HMRC on 9 December 2010 upholding the decision in the closure notice.
The HMRC case is that the bank statements showed the following deposits in excess of the returned turnover of �4,714, which in the absence of evidence to the contrary were considered by HMRC in the closure notice to be omitted income:
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