Steven Hague v The Commissioners for HM Revenue and Customs [2024] UKUT 00436 (TCC)
Upper Tribunal Tax and Chancery Decision of Judge Rupert Jones on 20 December 2024
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The Applicant, Mr Steven Hague, applies to the Upper Tribunal (Tax and Chancery) (“UT”) for permission to appeal the decision of the First-tier Tribunal (Tax Chamber) (“the FTT”), released on 19 February 2024 (“the Decision”). The appeal was decided by the FTT following a hearing conducted on 12 May 2023. 2. The FTT dismissed the Applicant’s appeal against the following decisions of HMRC: a) nine assessments (‘Discovery Assessments’) issued by the respondents (‘HMRC’) pursuant to s 29 of the Taxes Management Act 1970 (‘TMA’) for the nine consecutive tax years from 2007-08 to 2015-16 in respect of unpaid income tax and capital gains tax. For the purposes of the appeal, the total of the nine discovery assessments stood at £67,177.01. b) nine penalty assessments (the ‘Penalties’) for failure to notify the relevant tax liabilities for the said years. The penalties were raised pursuant to section 7 of TMA (for the years 2007-08 and 2008-09), and Schedule 41 to the Finance Act 2008 (‘Sch 41’) (for the years 2009-10 to 2015-16). The overall quantum of penalties for the nine years was £43,665.06.