In JR Hanson v HMRC (TC02000 – 1 June) an individual (H) disposed of some loan notes in 2008/09 giving rise to a substantial CGT liability. In his return he completed Box 20 indicating that he was making a claim for relief but without giving details of the relief. HMRC began an enquiry and after correspondence H accepted that he was not entitled to relief under TCGA 1992 s 135. HMRC imposed a penalty under FA 2007 Sch 24. H appealed contending that he had relied upon his accountants who had told him that he was entitled to relief and had therefore taken ‘reasonable care’ within FA 2007 Sch 24 para 18. The First-tier Tribunal accepted this contention and allowed the appeal. Judge Cannan held that ‘the effect of paragraph 18 is to remove...
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In JR Hanson v HMRC (TC02000 – 1 June) an individual (H) disposed of some loan notes in 2008/09 giving rise to a substantial CGT liability. In his return he completed Box 20 indicating that he was making a claim for relief but without giving details of the relief. HMRC began an enquiry and after correspondence H accepted that he was not entitled to relief under TCGA 1992 s 135. HMRC imposed a penalty under FA 2007 Sch 24. H appealed contending that he had relied upon his accountants who had told him that he was entitled to relief and had therefore taken ‘reasonable care’ within FA 2007 Sch 24 para 18. The First-tier Tribunal accepted this contention and allowed the appeal. Judge Cannan held that ‘the effect of paragraph 18 is to remove...
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