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James Ronaldson Scott v HMRC

In James Ronaldson Scott v HMRC [2015] UKFTT 420 (27 August 2015) the FTT found that HMRC’s decision not to allow special relief had been unreasonable.
Under TMA 1970 Sch 1AB para 3A (special relief) HMRC can allow a claim for relief of overpaid tax when more than four years have elapsed since the end of the relevant tax year. The first condition is that it would be unconscionable for HMRC to seek to recover the amount.
Mr Scott had made a formal request for special relief explaining that the returns were late ‘due to the serious sickness over a prolonged period and subsequent death of his previous accountant’. He also contended that the determinations by HMRC had been excessive. HMRC had refused the claim for special relief on the basis that Mr Scott...

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