Raza Miah v The Commissioners for HMRC

Facts

Raza Miah appealed against discovery assessments raised under section 29 of the Taxes Management Act 1970 for the tax years 2005/06 to 2013/14, together with penalty determinations under section 7 of the Taxes Management Act 1970 and penalty assessments under Schedule 41 to the Finance Act 2008. Officer Stoddart of HMRC opened an investigation in February 2014 after concerns about failure to notify chargeability and substantial unexplained bank deposits; no returns had been filed for any year between 2000/01 and 2013/14 save 2008/09 and 2009/10, and those declared no property income. Despite an information notice under Schedule 36 of the Finance Act 2008 and four successive agents, much of the bank, credit card and casino material was never produced, and estimated assessments were issued on 24 March 2015, varied by a Review Conclusion letter dated 14 December 2016 to £415,942.10, with penalties of £214,980.18. Meanwhile four of the appellant's brothers sued him in the High Court claiming beneficial interests in seventeen disputed properties; judgment was given against him and the proceedings were finally settled by a Tomlin Order in March 2025. Before the Tribunal he abandoned his original case and relied solely on that litigation and on the litigation costs as deductible expenditure.