Egan v Revenue & Customs (INCOME TAX - earlier decision in principle) [2020] UKFTT 241 (TC) (01 June 2020)

The tribunal found that Mr Egan was overcharged by the assessments and penalties, as the only reliable figures were CIS deductions. His behaviour was careless, not deliberate, so penalties were reduced to 30% of the potential lost revenue. Assessments and penalties were recalculated accordingly.

Citation: [2020] UKFTT 241
Parties: Appellant: Martin Egan; Respondents: The Commissioners for Her Majesty’s Revenue and Customs
Jurisdiction: United Kingdom
Judgment Date: 01 June 2020
Procedural Posture: Income Tax Appeal / Full Decision Following Earlier Decision in Principle and Summary Decision
Outcome: Appeal allowed in part
Legal Topics: Income Tax, Self Assessment, Discovery Assessments, Penalties, Careless Behaviour, Deliberate Behaviour

Tax Law Income Tax Self Assessment Discovery Assessments Penalties Careless Behaviour Deliberate Behaviour

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 2 Authorities cited 2 Party arguments 2 Amounts and remedies 5

Parties

Martin Egan

Appellant

The Commissioners for Her Majesty’s Revenue and Customs

Respondents

Procedural Posture

Income Tax Appeal / Full Decision Following Earlier Decision in Principle and Summary Decision

Legal Issues

1 Whether Mr Egan was overcharged by self-assessment and discovery assessments for tax years 2009-10 to 2014-15
2 Whether penalties imposed were appropriate and at the correct rate
3 Whether Mr Egan's behaviour was deliberate or careless

Ratio Decidendi

Court Disposition

Appeal allowed in part

Orders

Assessments and penalties under appeal reduced in accordance with recalculated figures
Overall total payable by Mr Egan set at £19,514.75