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A Salmon v HMRC

In A Salmon v HMRC (TC02711 – 23 May) HMRC began an enquiry into the 2009/10 return submitted by a trader (S) who owned a yacht chartering business. While the enquiry was in progress HMRC issued a protective estimated assessment for 2007/08. S did not pay the tax charged by the assessment and HMRC imposed a surcharge against which S appealed. The First-tier Tribunal allowed his appeal. Judge Redston observed that since the tax liability had not been finalised S could have applied for postponement of the tax and held that the circumstances constituted a reasonable excuse.

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Why it matters: The First-tier Tribunal held that since the tax liability had not been finalised the appellant had a reasonable excuse for not paying the tax which HMRC had assessed.

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