F Harber v HMRC

In F Harber v HMRC [2023] UKFTT 1007 (TC) (4 December 2023) the First-tier Tribunal (FTT) held that the taxpayer did not have a reasonable excuse for failing to notify HMRC of a liability to CGT. It also found that several cases cited in support of the taxpayer’s arguments had been generated by an artificial intelligence system and were not genuine FTT decisions.

The taxpayer (H) had failed to notify HMRC of a liability to CGT on the disposal of a UK residential property. HMRC issued a ‘failure to notify’ penalty and the taxpayer appealed against that penalty arguing she had a reasonable excuse on the grounds of (i) ignorance of the law and (ii) her mental health.

H put forward a written document citing nine FTT decisions in support of her arguments on both grounds and which had been given to her by ‘a friend in a solicitor’s office’....

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