In G Pitcher v HMRC [2017] UKFTT 406 (9 May 2017) the FTT found that a penalty imposed for non-compliance with an APN which had stated two different amounts of tax due was not due.
This was an appeal against a penalty for failure to make a payment under an APN. The issues were whether the APN in question was ‘given’ to the appellant whether his liability to a penalty should be affected by claimed rights to repayment of tax and whether the appellant had a reasonable excuse for non-payment.
The FTT found that the APN had been served; HMRC had sent it by post to the taxpayer’s known place of residence and it had been delivered at that address. The tribunal added that it had no role in deciding whether the conditions for the issue of an APN were satisfied. This matter could only be...
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