Mabbutt and HMRC declined to comment.

“The taxpayer has to be made aware that the inquiry phase is underway,” Mabbutt’s lawyer Keith Gordon told the judges. “The notice was not sufficiently clear.”

HMRC also opened probes into his finances for the years ending 2008 and 2010. Its legal documents didn’t identify the disputed scheme that Mabbutt disclosed in his 2009 return, or reveal the status of the other inquiries.

The two-judge panel ended the hearing Thursday afternoon saying that a ruling would be issued later.

This article was provided by Bloomberg News.
 

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