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J Hannigan v HMRC

Administration and appeals: Application for costs

In J Hannigan v HMRC (TC00447 – 22 April) an individual (H) had failed to submit tax returns and HMRC had issued estimated assessments. Subsequently H submitted late returns showing very low income and HMRC agreed to withdraw the assessments. H applied for costs. The First-Tier Tribunal rejected his application holding that HMRC had not acted unreasonably.

Why it matters: The Tribunal will only award costs where HMRC have acted 'wholly unreasonably'. There is no point in applying for costs where this is clearly not the case.

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