In J Hannigan v HMRC (TC00447 – 22 April) an individual (H) had failed to submit tax returns and HMRC had issued estimated assessments. Subsequently H submitted late returns showing very low income and HMRC agreed to withdraw the assessments. H applied for costs. The First-Tier Tribunal rejected his application holding that HMRC had not acted unreasonably.
Why it matters: The Tribunal will only award costs where HMRC have acted 'wholly unreasonably'. There is no point in applying for costs where this is clearly not the case.
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In J Hannigan v HMRC (TC00447 – 22 April) an individual (H) had failed to submit tax returns and HMRC had issued estimated assessments. Subsequently H submitted late returns showing very low income and HMRC agreed to withdraw the assessments. H applied for costs. The First-Tier Tribunal rejected his application holding that HMRC had not acted unreasonably.
Why it matters: The Tribunal will only award costs where HMRC have acted 'wholly unreasonably'. There is no point in applying for costs where this is clearly not the case.
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:
