Owens v Revenue and Customs (Income Tax - notices by Appellant to Self-Assessment - insufficient information) [2024] UKFTT 192 (TC) (06 March 2024)

Owens v Revenue and Customs (Income Tax - notices by Appellant to Self-Assessment - insufficient information) [2024] UKFTT 192 (TC) (06 March 2024)

The Appellant's notifications to HMRC did not contain sufficient information to enable HMRC to identify the tax type, source, or quantum of liability, and therefore did not satisfy the statutory requirements under s7 TMA 1970. HMRC's discovery assessments and penalties were validly issued within the statutory time...

Source-derived case information.

Citation
[2024] UKFTT 192
Parties
Appellant: Finola Owens; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
06 March 2024
Procedural Posture
Income Tax Appeal / First Tier Tribunal (tax Chamber) Substantive Decision
Outcome
Appeal dismissed
Legal Topics
Income Tax, Self Assessment, Discovery Assessments, Penalties for Failure to Notify, Statutory Notification Requirements
Tax Law Income Tax Self Assessment Discovery Assessments Penalties for Failure to Notify Statutory Notification Requirements

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Parties

Finola Owens

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Income Tax Appeal / First Tier Tribunal (tax Chamber) Substantive Decision

Legal Issues

  1. 1 Whether the Appellant's notifications to HMRC satisfied the statutory requirements under s7 TMA 1970 for notifying chargeability to income tax
  2. 2 Whether HMRC's discovery assessments and penalties were validly issued within statutory time limits
  3. 3 Whether the penalties for failure to notify were lawfully imposed

Ratio Decidendi

The Appellant's notifications to HMRC did not contain sufficient information to enable HMRC to identify the tax type, source, or quantum of liability, and therefore did not satisfy the statutory requirements under s7 TMA 1970. HMRC's discovery assessments and penalties were validly issued within the statutory time limits and calculated in accordance with statute. The appeal was dismissed as the Appellant failed to demonstrate any overcharge or special circumstances.

Court Disposition

Appeal dismissed