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The courts have given their support for the view that in certain circumstances evidence of omissions from one or more years' returns permits the Inspector to infer that omissions will have continued in earlier years.
A 'presumption of continuity' can be made and the Inspector can be entitled to conclude that under-declarations in some years can be taken as a pointer to under-declaration in earlier years and make discovery assessments accordingly.
Once the assessments are made and appealed against, the onus is on the appellant (taxpayer) to displace them.