New Claire Wine Ltd v The Commissioners for HMRC

Admissibility of evidence in tax tribunals is broad, not constrained by section 9 of the Civil Evidence Act 1995.

Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009, Rule 15

In best judgment assessments, HMRC must fairly consider all material before them and reach a reasonable, non-arbitrary decision. Extensive investigation is not required if sufficient material exists.

Van Boeckel v C & E Commissioners [1981] STC 290; C A McCourtie LON/92/191; Rahman (t/a Khayam Restaurant) v Commissioners of Customs and Excise [2002] EWCA Civ 1881; Pegasus Birds Ltd v Commissioners of HM Customs and Excise [2004] EWCA Civ 1015

Discovery assessments are permissible if an officer believes (and a reasonable officer could believe) that there's insufficient tax assessed, whether due to careless or deliberate behavior.

Schedule 18 Finance Act 1998; Jerome Anderson v HMRC [2018] UKUT 0159 (TCC)

A deliberate inaccuracy in a tax return occurs when a taxpayer knowingly provides an inaccurate document with the intention that HMRC relies on it.

Auxilium Project Management Ltd v HMRC [2016] UKFTT 249 (TC)

Tax disputes generally fall outside the scope of Article 6 of the European Convention on Human Rights.

R (oao ToTel Limited) v the FTT and another [2011] EWHC 652

Presumption of continuity applies to tax liabilities unless the taxpayer demonstrates a change in circumstances.

Jonas v Bamford 1973 51 TC; Dr I Syed v HMRC [2011] UKFTT 315 (TC)