In S Denny v HMRC (TC02714 – 23 May) HMRC formed the opinion that a company director (D) had failed to declare benefits and had underdeclared other income. They issued assessments (and amendments to D’s self-assessments) and imposed penalties at the rate of 50% of the tax allegedly evaded. D appealed. The First-tier Tribunal reviewed the evidence in detail and upheld the assessments in principle but reduced them in amount. The tribunal upheld the imposition of penalties at 50% in respect of the majority of the undeclared income and benefits (but directed that the penalty relating to the use of a motorboat should be reduced to 45% of the evaded tax and that the penalty relating to the CGT due on the sale of a flat should be reduced to 35% of the evaded tax).
In S Denny v HMRC (TC02714 – 23 May) HMRC formed the opinion that a company director (D) had failed to declare benefits and had underdeclared other income. They issued assessments (and amendments to D’s self-assessments) and imposed penalties at the rate of 50% of the tax allegedly evaded. D appealed. The First-tier Tribunal reviewed the evidence in detail and upheld the assessments in principle but reduced them in amount. The tribunal upheld the imposition of penalties at 50% in respect of the majority of the undeclared income and benefits (but directed that the penalty relating to the use of a motorboat should be reduced to 45% of the evaded tax and that the penalty relating to the CGT due on the sale of a flat should be reduced to 35% of the evaded tax).
