In Dr Gibson (deceased) v HMRC [2020] UKFTT 439 (TC) (3 November 2020) the taxpayer did have reasonable excuse for failing to notify claim for enhanced protection in time. This was due to justifiable reliance on professional advisers who have since admitted making a mistake. As ever this is a fact-specific decision but it is worth reading for the way that the tribunal approach the question of when it is reasonable for a taxpayer to rely on the advice of an expert.
Executors of the late Sheriff G L Cox v HMRC [2020] UKFTT 442 (TC) (3 November 2020) concerns whether a holiday letting activity qualifies for business property relief or is a business of making and holding investments. What is striking here is that faced with a marked difference between the picture of how the business operated presented by...
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