D Beadle v HMRC

In D Beadle v HMRC [2019] UKUT 101 (1 April 2019) the UT dismissed Mr Beadle’s appeal against a penalty imposed by HMRC for non-payment of a partner payment notice (PPN).

Mr Beadle had participated in a known marketed tax avoidance scheme involving a partnership called Ingenious Film Partners which had claimed trading losses. HMRC had opened an inquiry into the partnership’s return and issued a closure notice reducing the trading loss to nil. The partnership had appealed.

In addition HMRC had issued Mr Beadle with a PPN requiring him to pay over £100 000. Mr Beadle had written to HMRC making representations but these had been rejected and HMRC had issued a penalty notice for non-payment of the PPN. Mr Beale had then paid the amount demanded but HMRC had upheld the penalty. This was an appeal against the penalty.

The FTT noted that Mr Beade contended that the...