Market leading insight for tax experts
View online issue

G Allen v HMRC

In G Allen v HMRC (TC00903 – 6 April) a dentist had formed the opinion that his accounts had overstated his profits because of errors by his previous accountant. He submitted a claim for error or mistake relief.

HMRC accepted the claim for 1993/94 onwards but rejected the claim for 1992/93 and earlier years on the grounds that it was outside the six-year time limit of TMA 1970 s 33(1) as then in force. In 2009 the dentist lodged an appeal to the First-tier Tribunal. The Tribunal struck out the appeal holding that it had no jurisdiction under SI 2009/273.

Why it matters: TMA 1970 s 33 was substituted by FA 2009 with effect from 1 April 2010 but the case remains relevant as an illustration of the principle that claims must be lodged within the time limits.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.