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HMRC v N Rogers and another

In HMRC v N Rogers and another [2019] UKUT 406 (30 December 2019) the UT found that a notice issued under TMA 1970 s 8 does not need to identify an HMRC officer responsible for the notice. 

HMRC appealed two decisions of the FTT which concerned penalties for late filing of self-assessment returns. 

HMRC’s first ground of appeal concerned the scope of the FTT’s jurisdiction. In Goldsmith [2019] UKUT 325 the UT had concluded that the FTT did have jurisdiction to consider an alleged defect of a notice to file issued under TMA 1970 s 8 when deciding whether a penalty for non-compliance was valid. HMRC contended that the Goldsmith decision had been wrongly decided but the UT disagreed with this ground of appeal.

HMRC also challenged the FTT’s conclusion that for a notice to be given ‘by an officer of the Board’ a named officer either had...

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