In M Goodman v HMRC [2019] UKFTT 550 (28 August 2019) the FTT found that HMRC had not shown that a notice to file had been served (TMA 1970 s 8) so that penalties for late filing were not due.
HMRC claimed that a notice to file a tax return for 2014/2015 had been sent to the appellant on or about 6 April 2015 to an address in Thailand which was the address held on record at that time. It also claimed that a notice to file for the year 2015/2016 had been sent to the appellant at that address on 6 April 2016. The taxpayer has since then corresponded from a different address in the UK. HMRC issued late filing penalties in relation to both years. The penalties for the earlier year were cancelled.
The FTT first had to decide whether to allow the late appeal in relation to...
