Fane v Revenue & Customs [2011] UKFTT 210 (TC) (25 March 2011)

Fane v Revenue & Customs [2011] UKFTT 210 (TC) (25 March 2011)

The appellant failed to exercise reasonable care in completing the tax return, making an innocent but careless error. The penalty was correctly imposed at the minimum rate for a prompted disclosure. HMRC's decision not to suspend the penalty was not flawed, as the error was a one-off event and no practical suspension condition could be set.

Citation
[2011] UKFTT 210
Parties
Appellant: Anthony Fane; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
25 March 2011
Procedural Posture
Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Income Tax, Penalty Assessment, Careless Inaccuracy, Suspension of Penalty

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 7 Party arguments 2 Amounts and remedies 4
Sign in to unlock

Parties

Anthony Fane

Appellant

The Commissioners for Her Majesty’s Revenue and Customs

Respondents

Procedural Posture

Appeal / Final Judgment

  1. 1 Whether the error on the income tax return was careless
  2. 2 Whether the penalty should be suspended under paragraph 14 Schedule 24 Finance Act 2007
  3. 3 Whether HMRC's decision not to suspend penalty was flawed

Ratio Decidendi

The appellant failed to exercise reasonable care in completing the tax return, making an innocent but careless error. The penalty was correctly imposed at the minimum rate for a prompted disclosure. HMRC's decision not to suspend the penalty was not flawed, as the error was a one-off event and no practical suspension condition could be set.

Court Disposition

Appeal dismissed

Orders

  • Penalty imposed for 2008-2009 tax year affirmed
  • Appeal against refusal to suspend penalty dismissed