Jaroslaw Krason v The Commissioners for HMRC

Mr Krason did not act deliberately or carelessly because he lacked financial and business knowledge, relied in good faith on a qualified accountant with a long-standing professional relationship, did not understand the documents or scheme, and had no intention to mislead HMRC; a reasonable taxpayer in his position would have acted similarly.

Parties: Appellant: Jaroslaw Krason; Respondents: The Commissioners for His Majesty’s Revenue and Customs
Jurisdiction: England and Wales
Judgment Date: 07 May 2026
Procedural Posture: Income Tax Penalty Appeal / Judgment After Full Hearing
Outcome: Appeal allowed
Legal Topics: Income Tax, Penalties, Deliberate Inaccuracy, Carelessness, Reliance on Professional Advice

Tax Law Income Tax Penalties Deliberate Inaccuracy Carelessness Reliance on Professional Advice

Case Brief

Summary, issues, holding and outcome

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Full judgment text Downloadable case file Legal principles 2 Authorities cited 10 Party arguments 2 Amounts and remedies 6

Parties

Jaroslaw Krason

Appellant

The Commissioners for His Majesty’s Revenue and Customs

Respondents

Procedural Posture

Income Tax Penalty Appeal / Judgment After Full Hearing

Legal Issues

1 Whether the appellant acted deliberately and concealed inaccuracies in his tax returns
2 Whether the appellant acted carelessly in relation to his tax affairs

Ratio Decidendi

Court Disposition

Appeal allowed

Orders

Penalties of £224,750 cancelled
HMRC to provide a plain-language explanation of the £164,000 debt calculation to the Tribunal and Mr Krason within 28 days