FTTTx CAPITAL GAINS TAX – assessment made outside ordinary time limit – s 36(1) TMA – whether loss of capital gains tax attributable to negligent conduct of taxpayer or a person acting on her behalf
JURISDICTION – whether First-tier Tribunal has jurisdiction to consider legitimate expectation and other public law arguments – construction of s 50(6) TMA
LEGITIMATE EXPECTATION – whether appellant had a legitimate expectation as a consequence of representations of HMRC either (i) that relief would apply to a gain on certain share disposals, and (ii) that no other reliefs would be available, at a time when a claim for EIS relief could have been made for a particular tax year
[2014] UKFTT 657 (TC)
Bailii
Capital Gains Tax
Updated: 17 December 2021; Ref: scu.534282
