Briggs v Revenue & Customs [2014] UKFTT 161 (TC) (06 February 2014)

There was no time to pay agreement in place by the penalty date and the appellant did not have a reasonable excuse for non-payment; the penalty was therefore properly imposed.

Citation: [2014] UKFTT 161
Parties: Appellant: Robert Briggs; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction: United Kingdom
Judgment Date: 06 February 2014
Procedural Posture: Tax Penalty Appeal / First Tier Tribunal Decision
Outcome: Appeal dismissed
Legal Topics: Income Tax, Corporation Tax, Self Assessment Penalties, Late Payment, Reasonable Excuse, Time to Pay Arrangements

Tax Law Income Tax Corporation Tax Self Assessment Penalties Late Payment Reasonable Excuse Time to Pay Arrangements

Case Brief

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Parties

Robert Briggs

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Tax Penalty Appeal / First Tier Tribunal Decision

Legal Issues

1 Whether a time to pay agreement was in place by the penalty date
2 Whether the appellant had a reasonable excuse for late payment
3 Whether HMRC acted contrary to the Taxpayers’ Charter

Ratio Decidendi

There was no time to pay agreement in place by the penalty date and the appellant did not have a reasonable excuse for non-payment; the penalty was therefore properly imposed.

Court Disposition

Appeal dismissed