Bevan v Revenue and Customs (INCOME TAX - property letting income received - failure to notify liability to income tax) [2024] UKFTT 586 (TC) (01 July 2024)

Bevan v Revenue and Customs (INCOME TAX - property letting income received - failure to notify liability to income tax) [2024] UKFTT 586 (TC) (01 July 2024)

The appellant failed to notify liability to income tax from property letting as required by section 7 of the Taxes Management Act 1970. Ignorance of the law and mistaken assumptions regarding income allocation do not constitute a reasonable excuse. Penalties were correctly charged and reduced for cooperation; no special circumstances apply.

Citation
[2024] UKFTT 586
Parties
Appellant: Roy Bevan; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
01 July 2024
Procedural Posture
Income Tax Penalty Appeal / Final Judgment
Outcome
Appeal dismissed
Legal Topics
Income Tax, Failure to Notify Liability, Property Letting Income, Penalties, Reasonable Excuse
Tax Law Income Tax Failure to Notify Liability Property Letting Income Penalties Reasonable Excuse

Case Brief

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Parties

Roy Bevan

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Income Tax Penalty Appeal / Final Judgment

Legal Issues

  1. 1 Whether penalties for failure to notify liability to income tax were correctly issued
  2. 2 Whether the appellant established a reasonable excuse for the failure

Ratio Decidendi

The appellant failed to notify liability to income tax from property letting as required by section 7 of the Taxes Management Act 1970. Ignorance of the law and mistaken assumptions regarding income allocation do not constitute a reasonable excuse. Penalties were correctly charged and reduced for cooperation; no special circumstances apply.

Court Disposition

Appeal dismissed

Orders

  • Penalties upheld as charged
  • No reduction for special circumstances