The Commissioners for HM Revenue and Customs v Nigel Rogers and Craig Shaw: [2019] UKUT 0406 (TCC)

Upper Tribunal Tax and Chancery decision of Mr Justice Zacaroli and Judge Richards on 30 December 2019.

Read the full decision in The Commissioners for HM Revenue and Customs v Nigel Rogers and Craig Shaw: [2019] UKUT 0406 (TCC) .

INCOME TAX – Penalties for late filing – Whether notice to file had to be issued by identified “flesh and blood” officer – no – whether Tribunal has jurisdiction to consider validity of notice to file in penalty appeal – yes - whether procedural unfairness in FTT taking a point without inviting submissions – yes – appeal allowed and decision remade.

Published 30 December 2019