Partial compliance not enough

The taxpayer was a barrister. He submitted his tax returns for 2008/09 2009/10 and 2010/11 in April 2012.

HMRC were not satisfied that the returns were correct and issued notices for further information. The taxpayer did not supply all the requested documents and the Revenue imposed penalties under FA 2008 sch 36 paras 39 and 40.

The taxpayer was liable to pay inheritance tax (IHT) as a result of his father’s death in 2005. The tax department had issued an information notice in relation to the IHT return with which the taxpayer had failed to comply.

HMRC applied for permission from the Upper Tribunal to impose fines under FA 2008 sch 36 para 50 in relations to the taxpayer’s personal returns and IHT return.

The tribunal decided to give the taxpayer a final chance to respond in full. He failed to do so and...