Lamuth v Revenue and Customs (Income tax - late filing penalty - whether reasonable excuse) [2025] UKFTT 856 (TC) (11 July 2025)
The appellant's mistaken belief, combined with her attempt to clarify her tax position with HMRC and the lack of response to her 2017 letter, amounted to a reasonable excuse for late payment. All penalties were raised during the period of reasonable excuse, so the appeal is allowed and penalties quashed.
- Citation
- [2025] UKFTT 856 (TC)
- Parties
- Appellant: Sayrun Lamuth; Respondents: The Commissioners for His Majesty's Revenue and Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 11 July 2025
- Procedural Posture
- Income Tax Penalty Appeal / First Tier Tribunal Decision
- Outcome
- Appeal allowed
- Legal Topics
- Income Tax, Late Payment Penalties, Reasonable Excuse, Self Assessment, Schedule 56 Finance Act 2009
Case Brief
Summary, issues, holding and outcome
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Parties
Sayrun Lamuth
Appellant
The Commissioners for His Majesty's Revenue and Customs
Respondents
Procedural Posture
Income Tax Penalty Appeal / First Tier Tribunal Decision
Legal Issues
- 1 Whether late payment penalties were correctly assessed
- 2 Whether penalty notices were correctly issued
- 3 Whether the appellant had a reasonable excuse for late payment
Ratio Decidendi
The appellant's mistaken belief, combined with her attempt to clarify her tax position with HMRC and the lack of response to her 2017 letter, amounted to a reasonable excuse for late payment. All penalties were raised during the period of reasonable excuse, so the appeal is allowed and penalties quashed.
Court Disposition
Appeal allowed
Orders
- All late payment penalties quashed
Full Case Text
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