In MJ Rayner v HMRC (TC02363 – 22 November) a solicitor failed to comply with a notice under TMA 1970 s 19A. HMRC imposed penalties under TMA 1970 s 97AA. The FTT upheld the penalties and dismissed the solicitor’s appeal.
Why it matters: TMA 1970 s 97AA provides statutory penalties for failure to comply with a notice under TMA 1970 s 19A. The FTT upheld the penalties which HMRC had imposed in this case and also upheld discovery assessments issued on the basis that the solicitor appeared to have overstated his expenditure. Judge Coverdale’s decision is worth reading in full as an illustration of the difficulties which HMRC sometimes encounter in attempting to administer the tax system.
