Pritt v Revenue & Customs (INCOME TAX - late appeal to HMRC) [2019] UKFTT 578 (TC) (13 September 2019)

Pritt v Revenue & Customs (INCOME TAX - late appeal to HMRC) [2019] UKFTT 578 (TC) (13 September 2019)

The Tribunal found that HMRC had properly issued and served all relevant notices and penalty notices, and that the appellant failed to demonstrate a reasonable excuse for late filing. The penalties were correctly calculated and imposed under Schedule 55 of the Finance Act 2009. No special circumstances or unfairness justified reduction. The appeal was dismissed and the penalties remain due.

Citation
[2019] UKFTT 578 (TC)
Parties
Appellant: Sandra Pritt; Respondents: The Commissioners for Her Majesty’s Revenue & Customs
Jurisdiction
United Kingdom
Judgment Date
13 September 2019
Procedural Posture
Income Tax Appeal Late Appeal to HMRC / First Tier Tribunal (tax Chamber) Substantive Decision
Outcome
Appeal dismissed
Legal Topics
Income Tax, Late Filing Penalties, Reasonable Excuse, Appeals Procedure
Tax Law Income Tax Late Filing Penalties Reasonable Excuse Appeals Procedure

Case Brief

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Parties

Sandra Pritt

Appellant

The Commissioners for Her Majesty’s Revenue & Customs

Respondents

Procedural Posture

Income Tax Appeal Late Appeal to HMRC / First Tier Tribunal (tax Chamber) Substantive Decision

Legal Issues

  1. 1 Whether HMRC issued valid notices to file and penalty notices for each relevant tax year
  2. 2 Whether the appellant had a reasonable excuse for late filing of self-assessment tax returns
  3. 3 Whether penalties were correctly calculated and imposed under Schedule 55 of the Finance Act 2009

Ratio Decidendi

The Tribunal found that HMRC had properly issued and served all relevant notices and penalty notices, and that the appellant failed to demonstrate a reasonable excuse for late filing. The penalties were correctly calculated and imposed under Schedule 55 of the Finance Act 2009. No special circumstances or unfairness justified reduction. The appeal was dismissed and the penalties remain due.

Court Disposition

Appeal dismissed

Orders

  • Penalties totalling £4,900.00 for tax years 2010-11, 2011-12, 2012-13, and 2014-15 are due and payable by the appellant.