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C Reid v HMRC

In C Reid v HMRC (Upper Tribunal – 28 November) HMRC issued assessments for 1996/97 to 2003/04 and imposed penalties under TMA 1970 s 95 at the rate of 45% of the evaded tax on an MC who had failed to maintain full records of his income. The First-tier Tribunal upheld the assessments and the penalties (but allowed appeals against estimated assessments for years before 1996/97). The MC appealed to the Upper Tribunal which dismissed his appeal holding that there was ‘no basis to disturb the Tribunal’s decision’.

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Why it matters: The Upper Tribunal upheld the FTT decision with regard to both the amount of the assessments and the amount of the penalties.

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