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Dorothy M Morris and another v HMRC

Contract settlements and the tax tribunals

In Dorothy M Morris and another v HMRC [2014] UKFTT 993 (27 October 2014) the FTT confirmed that it does not have the jurisdiction to hear appeals about contract settlements negotiated with HMRC.

On the death of Mr Sutton his farm (valued at £650 000 at the time of death) had been left on trust to his four sisters including Mrs Morris. The farm had then been sold and the executors had claimed capital losses on the disposal. HMRC rejected the claim and the value of the farm was referred to the District Valuer who found that the value at death had been £740 000.

HMRC then informed Mrs Morris that they would seek to negotiate a contract settlement of the tax and penalties due. An offer by the appellants was duly accepted by HMRC and the tax was paid....

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