Richard Curtis considers the difficulties of contending that gift and certain other receipts should not be taxed.
The question of whether monetary or, indeed, other receipts are subject to tax is naturally of central importance when considering liability. Generally, it will be obvious whether a trade, profession or employment is being carried on or whether interest, dividends and the like are being received. The general principle is that all amounts received in connection with the business should be included in accounts.
Occasionally, however, a dispute may arise on this fundamental subject and one such was the recent case of Stephen Mullens v HMRC [2021] UKFTT 131 (TC) TC08112.
Substantial receipts
In that case, the appellant, Mr Mullens, was engaged in the business affairs of Mr Bernie
