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Patrick v Her Majesty’s Revenue and Customs: FTTTx 15 Oct 2015

FTTTx INCOME TAX – Permission to give late notice of appeal – s 49(2) TMA 1970 – penalty under para 3 Sch 55 FA 2009 – whether assessment of penalty notified – no – permission granted – effect of non-notification on validity of penalty assessment – none – whether reasonable excuse – no – whether special reduction justified – no – assessment confirmed.
PROCEDURE – Withdrawal of case under Rule 17 First-tier Tribunal Rules in default paper case – whether possible after consideration on paper and before final decision issued – yes – meaning of withdrawal of ‘case’ in Rule 17 – whether Tribunal may make a decision after Rule 17 withdrawal – yes – effect of s 54 TMA agreement.
References: [2015] UKFTT 508 (TC)
Links: Bailii
Jurisdiction: England and Wales

Last Update: 15 October 2020; Ref: scu.556169 br>

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