The High Court has rejected a retired farmer's challenge to tax assessments totalling more than €364,000 after finding that Revenue's use of documents obtained from third parties did not make the process unfair.
In a judgment delivered on 14 November 2025, Mr Justice Oisín Quinn answered all three legal questions raised by Peadar Hamill against him and upheld the approach taken by the Tax Appeals Commission.
Revenue had concluded following an audit that Hamill understated his income between 2013 and 2015 and failed to charge VAT on agricultural products sold in 2013 and 2015. During the tax appeal, Revenue acknowledged calculation errors and reduced the assessments to €237,551.48 in income tax and €126,963.97 in VAT.
Hamill did not challenge the commission's factual findings or its rejection of his explanations for substantial differences between his declared income and bank lodgements. His High Court appeal instead focused on procedure.
He argued that Revenue had obtained documents from third parties without providing them to him before the assessments were made and that the material should therefore have been excluded from the Tax Appeals Commission hearing. The documents included statements from Hamill's own bank accounts, cheques drawn on those accounts and receipts or invoices he had issued to customers.
The High Court found that the disputed material was information Hamill himself had, or had previously had, access to. It also noted the unchallenged finding that he had failed to cooperate with Revenue's audit, forcing officials to obtain information elsewhere.
Mr Justice Quinn said Hamill had been informed that Revenue was gathering third-party material and had been offered opportunities to meet officials but had not taken them up. His accountant had also written to Revenue stating that Hamill was no longer prepared to assist or cooperate.
The court therefore held that the requirements of EU fair-procedure law had been met. It found no legal error in admitting the evidence and no failure by the Tax Appeals Commission to apply the relevant European Court principles correctly.