In D Beadle v HMRC [2019] UKUT 101 (1 April 2019) the UT dismissed Mr Beadle’s appeal against a penalty imposed by HMRC for non-payment of a partner payment notice (PPN).
Mr Beadle had participated in a known marketed tax avoidance scheme involving a partnership called Ingenious Film Partners which had claimed trading losses. HMRC had opened an inquiry into the partnership’s return and issued a closure notice reducing the trading loss to nil. The partnership had appealed.
In addition HMRC had issued Mr Beadle with a PPN requiring him to pay over £100 000. Mr Beadle had written to HMRC making representations but these had been rejected and HMRC had issued a penalty notice for non-payment of the PPN. Mr Beale had then paid the amount demanded but HMRC had upheld the penalty. This was an appeal against the penalty.
The FTT noted...
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In D Beadle v HMRC [2019] UKUT 101 (1 April 2019) the UT dismissed Mr Beadle’s appeal against a penalty imposed by HMRC for non-payment of a partner payment notice (PPN).
Mr Beadle had participated in a known marketed tax avoidance scheme involving a partnership called Ingenious Film Partners which had claimed trading losses. HMRC had opened an inquiry into the partnership’s return and issued a closure notice reducing the trading loss to nil. The partnership had appealed.
In addition HMRC had issued Mr Beadle with a PPN requiring him to pay over £100 000. Mr Beadle had written to HMRC making representations but these had been rejected and HMRC had issued a penalty notice for non-payment of the PPN. Mr Beale had then paid the amount demanded but HMRC had upheld the penalty. This was an appeal against the penalty.
The FTT noted...
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