McCrae v Revenue & Customs [2009] UKFTT 55 (TC) (22 April 2009)

McCrae v Revenue & Customs [2009] UKFTT 55 (TC) (22 April 2009)

The appellant failed to discharge the onus of proof by not providing satisfactory evidence to challenge HMRC's assessments and amendments; late appeals were refused due to lack of reasonable excuse.

Citation
[2009] UKFTT 55
Parties
Appellant: Mrs Moira McCrae; Respondents: The Commissioners for Her Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
22 April 2009
Procedural Posture
Tax Appeal / Final Judgment
Outcome
Appeals dismissed
Legal Topics
Income Tax Assessment, Self Assessment Amendment, Late Appeals, Onus of Proof, Business Records
Tax Law Income Tax Assessment Self Assessment Amendment Late Appeals Onus of Proof Business Records

Case Brief

Summary, issues, holding and outcome

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Parties

Mrs Moira McCrae

Appellant

The Commissioners for Her Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Final Judgment

Legal Issues

  1. 1 Whether the appellant provided sufficient evidence to challenge HMRC's assessments and amendments
  2. 2 Whether late appeals should be admitted
  3. 3 Whether deductions for wages and income from property letting were substantiated

Ratio Decidendi

The appellant failed to discharge the onus of proof by not providing satisfactory evidence to challenge HMRC's assessments and amendments; late appeals were refused due to lack of reasonable excuse.

Court Disposition

Appeals dismissed

Orders

  • Application to bring late appeals out of time refused
  • Appeals against assessments and amendment dismissed in their entirety