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The taxpayer, a parish council, claimed that it had submitted its end-of-year return online by the deadline. Due to a problem with HMRC’s systems, the department did not record its receipt.
The council clerk could not say for sure that an automatic acknowledgement had been received and thought she might have deleted it. She asserted had she been in any doubt, she would have contacted HMRC.
The First-tier Tribunal concluded that, on the evidence, it was improbable the HMRC system would receive a return and not generate a confirmation message. It therefore was likely the return was not received.
Had the taxpayer’s attempt to submit a return online been successful, it should have been clear that the attempt failed. There was therefore no reasonable excuse for the late submission.
The taxpayer’s appeal was dismissed.
