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Private client briefing for September 2015

In this month’s briefing, Andrew Goldstone and Jeffrey Lee (Mischcon de Reya) review the key developments in the private client arena, including the recent decisions in Scott, Blackwell, Ames, Fountain and HCS Trustees.

Scott: HMRC’s refusal to allow special relief held to be Wednesbury unreasonable

 
In James Ronaldson Scott v HMRC [2015] UKFTT 0420 the taxpayer filed his self-assessment returns late. By then HMRC had already issued determinations and his only recourse from those determinations was the special relief regime.  The taxpayer made a formal request for special relief on the basis that his returns were late ‘due to the serious sickness over a prolonged period and subsequent death of his previous accountant’.  He also argued that the determinations were excessive in relation to the...

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