FTTTx INCOME TAX – HMRC determinations for 2005-06 and 2006-07 – appellant out of time to displace determinations – claim for special relief under TMA Sch 1AB para 3A – whether the Tribunal has a free-standing jurisdiction to decide that collection of the tax is ‘unconscionable’ – whether jurisdiction limited to considering the reasonableness of HMRC’s opinion on unconscionability – whose opinion is ‘the opinion of the Commissioners’ – the factual basis of the opinion – whether the opinion in this case was unreasonable in a judicial review sense – held, no – appeal dismissed
[2014] UKFTT 882 (TC)
Bailii
England and Wales
Income Tax
Updated: 21 December 2021; Ref: scu.536739
