In G Bull v HMRC [2019] UKFTT 307 (10 May 2019) the FTT found that the taxpayer could not rely on reasonable excuse to extend the deadline to resile from a TMA 1970 s 54 agreement.
Mr Bull was a self-employed builder and plasterer. He also had a property rental business. An enquiry into his tax return for 2003/04 was taken over by HMRC Civil Investigation Team in 2008. Mr Bull became subject to a Code of Practice 9 investigation. HMRC issued closure notices assessments and penalty determinations in September 2010. There were 16 closure notices and assessments for income tax and/or capital gains tax and 13 penalty determinations in respect of tax years from 1996/97 to 2010/11. Mr Bull appealed against the assessments and determinations and an agreement under TMA 1970 s 54 was eventually reached in December 2013. In July 2014 HMRC issued proceedings to recover the amounts. Mr Bull’s...
