Paul Judd v The Commissioners for HMRC
There was sufficient identification between the appellant and the company in the previous VAT litigation such that it would be an abuse of process to allow the appellant to challenge the existence of inaccuracies in the company's VAT returns in his appeal against the personal liability notice. The application to amend the grounds of appeal to include this challenge is refused. However, the appellant is permitted to pursue grounds relating to whether any inaccuracy was deliberate and whether it was attributable to him.
Source excerpt
- Value added tax (vat)
- Schedule 24 finance act 2007 penalties
- Personal liability notice (pln)
- Abuse of process
- Burden of proof
- Finality in litigation