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D F Currie (TC3997)
The taxpayer was a barrister’s clerk who was paid on a commission basis. He also owned several properties which he let out.
He did not submit self assessment returns for 2005/06 2006/07 and 2007/08 leading HMRC to issue determinations that charged tax of £10 000 for each of the first two years and £100 000 for the third.
The taxpayer filed the returns at the end of 2012 making him out of time to displace the determinations.
He claimed special relief covered in TMA 1970 sch 1AB para 3A which applies when the collection of tax would be unconscionable.
The Revenue refused the claim and the taxpayer appealed.
The department withdrew the 2007/08 determination shortly before proceedings began before the First-tier Tribunal.
The issue for the tribunal was whether or not its jurisdiction was limited to deciding if HMRC was being unreasonable by...
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