In J Bell v HMRC [2018] UKFTT 261 (9 May 2018) the FTT upheld HMRC’s application to strike out the appeal on the ground that it did not have jurisdiction.
Mr Bell contended that HMRC should have waived his liability to income tax because he was entitled to the benefit of extra-statutory concession A19. This concession applies where various conditions are met one of which is that before being notified of the relevant tax arrears the taxpayer must have formed the reasonable belief that ‘his or her tax affairs were in order’.
HMRC considered that it had not been reasonable for Mr Bell to hold that belief given the level of his earnings and the amount of tax he was paying. More importantly HMRC contended that the FTT did not have jurisdiction to hear Mr Bell’s appeal so that it should be struck...
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