A firm of solicitors owed tax to HMRC. Failure to pay led HMRC to petition for the partners to be made bankrupt.
Subsequently the practice was terminated by the Solicitors Regulation Authority and the debtors then offered legal charges over various properties as security for payment.
HMRC would not accept the offer for a number of reasons including:
- there was no guarantee when payment would happen;
- settlement of the debt was required in full;
- they were not set up to administer property deals to pay tax debts;
- the debtors had had plenty of time in which to raise finance on their properties;
- it would be unfair on other taxpayers.
At the bankruptcy hearing the registrar decided that it was reasonable within the meaning of
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