HENRY RAFFERTY v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2025] UKUT 00063 (TCC)

Upper Tribunal Tax and Chancery Decision of Judges Nicholas Aleksander and Kevin Poole 19-02-2025

• From: HM Courts & Tribunals Service and Upper Tribunal (Tax and Chancery Chamber)
• Published: 19 February 2025

• Category: Tax
• Release date: 19 February 2025

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INCOME TAX – discovery assessment and penalties for deliberate behaviour – adequacy of reasons given by First-tier Tribunal – consideration of decision of Court of Appeal in English v Emery Reimbold & Strick – review of FTT’s reasons in the context of HMRC statement of case and skeleton argument - appeal dismissed

HENRY RAFFERTY v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2025] UKUT 00063 (TCC) HENRY RAFFERTY v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2025] UKUT 00063 (TCC)

Published 19 February 2025