M Fox v HMRC [2022] UKFTT 138 (TC) (14 April) is a robust judgment in which taxpayer’s application for costs was dismissed and it is clear that the judge was not impressed by the way that the costs claim had been put together. According to the FTT HMRC did not behave unreasonably in not appreciating that the taxpayer's time limit argument (i.e. that the time limit to pay an APN cannot start to run if HMRC ignores representations made) raised in Exclusive Promotions and Fox [2022] UKFTT 103 (TC) was supported by a Court of Appeal decision. The taxpayer had failed to include the Court of Appeal decision in its skeleton or in its authorities bundle and it is not unreasonable for HMRC not to know every case to which it is a party. Read the decision.
Late appeal...
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M Fox v HMRC [2022] UKFTT 138 (TC) (14 April) is a robust judgment in which taxpayer’s application for costs was dismissed and it is clear that the judge was not impressed by the way that the costs claim had been put together. According to the FTT HMRC did not behave unreasonably in not appreciating that the taxpayer's time limit argument (i.e. that the time limit to pay an APN cannot start to run if HMRC ignores representations made) raised in Exclusive Promotions and Fox [2022] UKFTT 103 (TC) was supported by a Court of Appeal decision. The taxpayer had failed to include the Court of Appeal decision in its skeleton or in its authorities bundle and it is not unreasonable for HMRC not to know every case to which it is a party. Read the decision.
Late appeal...
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