Penalties
In C Reid v HMRC (Upper Tribunal – 28 November) HMRC issued assessments for 1996/97 to 2003/04 and imposed penalties under TMA 1970 s 95 at the rate of 45% of the evaded tax on an MC who had failed to maintain full records of his income. The First-tier Tribunal upheld the assessments and the penalties (but allowed appeals against estimated assessments for years before 1996/97). The MC appealed to the Upper Tribunal which dismissed his appeal holding that there was ‘no basis to disturb the Tribunal’s decision’.
Why it matters: The Upper Tribunal upheld the FTT decision with regard to both the amount of the assessments and the amount of the penalties.
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Penalties
In C Reid v HMRC (Upper Tribunal – 28 November) HMRC issued assessments for 1996/97 to 2003/04 and imposed penalties under TMA 1970 s 95 at the rate of 45% of the evaded tax on an MC who had failed to maintain full records of his income. The First-tier Tribunal upheld the assessments and the penalties (but allowed appeals against estimated assessments for years before 1996/97). The MC appealed to the Upper Tribunal which dismissed his appeal holding that there was ‘no basis to disturb the Tribunal’s decision’.
Why it matters: The Upper Tribunal upheld the FTT decision with regard to both the amount of the assessments and the amount of the penalties.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: