PITTNER v Revenue & Customs (INCOME TAX - HIGH INCOME CHILD BENEFIT CHARGE (HICBC)) [2021] UKFTT 410 (TC) (16 November 2021)
The penalties for failure to notify liability to HICBC are valid and stand independently of the invalid discovery assessments, as the statutory requirements for penalty assessment were met and no reasonable excuse was shown by the appellant.
- Citation
- [2021] UKFTT 410 (TC)
- Parties
- Appellant: Mr Chris Pittner; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 16 November 2021
- Procedural Posture
- Appeal Against Penalty Notices (tax) / First Tier Tribunal (tax Chamber) Decision
- Outcome
- Appeal dismissed
- Legal Topics
- Income Tax, High Income Child Benefit Charge (hicbc), Failure to Notify Penalties, Self Assessment, Discovery Assessments
Case Brief
Summary, issues, holding and outcome
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Parties
Mr Chris Pittner
Appellant
The Commissioners for Her Majesty’s Revenue & Customs
Respondents
Procedural Posture
Appeal Against Penalty Notices (tax) / First Tier Tribunal (tax Chamber) Decision
Legal Issues
- 1 Whether penalties for failure to notify liability to HICBC are valid when discovery assessments are invalid
- 2 Whether the appellant had a reasonable excuse for failing to notify liability to HICBC
Ratio Decidendi
The penalties for failure to notify liability to HICBC are valid and stand independently of the invalid discovery assessments, as the statutory requirements for penalty assessment were met and no reasonable excuse was shown by the appellant.
Court Disposition
Appeal dismissed
Orders
- The appeal against the penalty notices is dismissed.
Full Case Text
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