HMRC issued a trust and estate tax return in April 2011 to the trustees of a settlement.
The completed return was received by the department on 1 November, one day after the deadline for paper returns. The Revenue imposed a late filing penalty of £100.
The trustees appealed, claiming they had posted the return on Friday 28 October in time for it to arrive on 31 October.
The First-tier Tribunal judge dismissed the taxpayer’s appeal by observing that it did not seem “to be the action of a reasonable and prudent taxpayer to post a return on the very last day before a deadline, especially with an intervening weekend”.