Higgins v National Crime Agency

Income tax – Assessment. Where a 'best judgment' tax assessment had been made by the Revenue and Customs Commissioners pursuant to s 29 of the Taxes Management Act 1970, the onus was on the taxpayer, by satisfactory evidence, to show that the assessment ought to be reduced or set aside. Applying that principle, the Upper Tribunal (Tax Chamber) dismissed the taxpayer's appeal against a decision of the First-tier Tribunal (Tax Chamber)(the FTT) in which the FTT had offset the amount paid by the taxpayer in respect of a confiscation order made against him, against tax that the respondent National Crime Agency (NCA) had claimed was owed by the taxpayer. The tribunal held that the taxpayer had failed to produce evidence to challenge the assessment of his tax liability made by the NCA.

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