Matthew Harrison v The Commissioners for Her Majesty’s Revenue and Customs

Matthew Harrison v The Commissioners for Her Majesty’s Revenue and Customs

The First-tier Tribunal did not err in law; Mr Harrison’s circumstances did not amount to a reasonable excuse or special circumstances, and the delay in filing was deliberate. The penalty imposed by HMRC stands.

Parties
Appellant: Matthew Harrison; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
Jurisdiction
England and Wales
Judgment Date
09 August 2022
Procedural Posture
Income Tax Appeal / Upper Tribunal (tax and Chancery Chamber) Appeal From First Tier Tribunal
Outcome
Appeal dismissed
Legal Topics
Late Filing Penalty, Reasonable Excuse, Special Circumstances, Deliberate Withholding of Information
Tax Law Late Filing Penalty Reasonable Excuse Special Circumstances Deliberate Withholding of Information

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 10 Party arguments 2 Amounts and remedies 1
Sign in to unlock

Parties

Matthew Harrison

Appellant

The Commissioners for Her Majesty’s Revenue and Customs

Respondents

Procedural Posture

Income Tax Appeal / Upper Tribunal (tax and Chancery Chamber) Appeal From First Tier Tribunal

Legal Issues

  1. 1 Whether the First-tier Tribunal erred in law regarding reasonable excuse for late filing
  2. 2 Whether special circumstances warranted a reduction of penalty
  3. 3 Whether information was deliberately withheld

Ratio Decidendi

The First-tier Tribunal did not err in law; Mr Harrison’s circumstances did not amount to a reasonable excuse or special circumstances, and the delay in filing was deliberate. The penalty imposed by HMRC stands.

Court Disposition

Appeal dismissed

Orders

  • The penalty imposed by HMRC is upheld.
  • No reduction for special circumstances.