Patrick Kearney v The Commissioners for His Majesty’s Revenue and Customs [2026] UKUT 00380 (TCC)
Upper Tribunal Tax and Chancery decision of JUDGE TRACEY BOWLER on 15 October 2026
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In the Decision the FTT refused the Applicant’s appeal of discovery assessments made under s.29 Taxes Management Act 1970 (“TMA”) for the years 2004/05, 2005/06, 2006/07 and a closure notice for the year 2009/10; as well as related penalty determinations issued on the basis that the Applicant had acted negligently/carelessly.