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Other cases that caught our eye: 3 March 2021

Discovery assessment

In Ball Europe Ltd [2021] UKFTT 23 (TC) (28 January 2021) the FTT found that the discovery assessment was precluded because the hypothetical officer could reasonably have been expected to be aware of the insufficiency of tax by virtue of an amount that was included in the statement of recognised gains and losses (STRGL) in the accounts enclosed with the tax return but which was not included on the tax return.

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ATED late filing penalties

In Bennedy’s Developments Ltd [2021] UKFTT 21 (TC) (27 January 2021) daily penalties were removed because of a lack of valid notice. Heacham Holidays Ltd [2020] UKFTT 406 (notice must predate the 90 days period in order that such a notice provided actual notification to the person affected) was followed.

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Reasonable excuse

In Robin St John Sellers [2021] UKFTT 27 (TC) (26 January 2021) the taxpayer...

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