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HMRC internal manual

National Insurance Manual

NICs Personal Liability Notices: PLN tribunal decisions

Section 121C, Social Security Administration Act 1992

Decisions by the independent Tax Tribunal in respect of Personal Liability Notice appeals include:

  1. First-Tier Tribunal, Tax: Michael Denmark v HMRC, TC06096, Released 6 September 2017
  2. First-Tier Tribunal, Tax: Charles O’Rorke v HMRC, TC06008, Released 14 July 2017
  3. Upper Tribunal, Tax: HMRC v Charles Michael O’Rorke, FTC/39/2012, Released 4 October 2013
  4. First-Tier Tribunal, Tax: Humayun Zubair v HMRC, TC02324, Released 22 October 2012
  5. First-Tier Tribunal, Tax: John Peter Smith v HMRC, TC02110, Released 28 June 2012
  6. First-Tier Tribunal, Tax: Mrs Christine Roberts v HMRC, TC01994, Released 11 April 2012
  7. First-Tier Tribunal, Tax: Stephen Roberts & Alan Martin v HMRC, TC01130, Released 26 April 2011
  8. First-Tier Tribunal, Tax: Leslie Livingstone v HMRC, TC00369, Released 3 February 2010

Whilst it’s recognised that the First-tier Tribunal decisions are not binding and do not set case precedent, as noted by Judge Amanda Brown in Charles O’Rorke v HMRC, they can be _‘_persuasive and illustrative of the approach to be taken’.

You can see the significance of the Upper Tribunal decision in HMRC v Charles Michael O’Rorke,  at NIM12204.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)