(1) Michael Burgess (2) Brimheath Developments Limited v The Commissioners for HM Revenue and Customs: [2015] UKUT 0578 (TCC)
Upper Tribunal Tax and Chancery decision of Judge Berner and Judge Scott on 27 October 2015.
Read the full decision in .
INCOME TAX/CORPORATION TAX 鈥� discovery assessments 鈥� competence issues 鈥� TMA, s 29 and FA 1998, Sch 18, paras 41鈥�43 鈥� time limit issues 鈥� TMA, s 36(1A) and FA 1998, Sch 18, para 46(2A) - whether failure by FTT to consider competence and time limit issues was an error of law 鈥� whether issues were required to be raised by HMRC or appellants 鈥� burden of proof 鈥� appeal allowed 鈥� whether to remit to FTT 鈥� case not remitted.