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R Gardner (TC3607)
The taxpayer was a solicitor who submitted his self assessment returns for 2010/11 and 2011/12 on time but was late paying the tax for each year.
HMRC imposed penalties. The taxpayer appealed against the fines in the belief his liability for the years would be reduced by terminal loss relief which arose in 2012/13.
He also had problems with his accountants and had suffered a large and unexpected reduction in his work following the decision in the payment protection insurance-related case of Harrison v Black Horse Ltd [2011] EWCA Civ 1128.
The First-tier Tribunal said the taxpayer could not rely on the actions of his previous adviser as a reasonable excuse for late payment.
On the outcome of Harrison v Black Horse Ltd the tribunal said a “reasonably competent businessman” would have been aware of the concept of litigation risk – and there was no reasonable...
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