AJ Bingham v HMRC

In AJ Bingham v HMRC (TC02528 – 20 February) a solicitor (B) opened bank and building society accounts in the joint names of him and his wife and subsequently opened further accounts in the joint names of him and one or more of his three children. In his tax returns he initially declared only a proportion of the interest received on these joint accounts treating the majority of the interest as accruing to his wife and children. Subsequently he did not declare any of the interest on his personal return apportioning the whole of it between his wife and children. HMRC issued assessments for 1996/97 to 2009/10 and imposed penalties on the basis that all the interest accruing on these joint accounts was taxable on B as the person ‘receiving...