FTTTx INCOME TAX – HMRC enquiry into 2010 SA return – unrepresented taxpayer – HMRC seeking to amend returns for the previous two years – HMRC issuing a protective assessment for 2007-08 – taxpayer failing to pay by surcharge trigger date – whether conditions for discovery assessment met – whether tax was due so as to trigger a surcharge for late payment -Tribunal’s jurisdiction considered – whether Tribunal can set aside surcharge if no underlying tax – held, no – whether Tribunal has jurisdiction to consider reasonable excuse – yes – whether taxpayer has reasonable excuse – yes – appeal allowed and surcharge set aside
Citations:
[2013] UKFTT 306 (TC)
Links:
Jurisdiction:
England and Wales
Income Tax
Updated: 13 October 2022; Ref: scu.513459