Post-cessation trade relief/notice of enquiry into return: There are two distinct aspects to A Dennison v HMRC [2024] UKFTT 364 (TC) (2 May 2024). The substantive issue is whether or not the taxpayer was entitled to claim relief under the post-cessation loss rules for payment to his former partners which were made as a result of his breach of fiduciary duties. The FTT concluded that the payments were not as the legislation requires payments by way of compensation for defective work in the course of the taxpayer’s profession as a partner in a law firm. As such no deduction was available.
However the taxpayer escaped the consequences of this finding because of the other issue in the case. This was the question of whether HMRC had raised a notice of enquiry into the relevant return within the one-year time limit. The decision on this matter goes into minute...
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