This week’s opinion

Sometimes the actual outcome of a tax case is not as interesting as the observations made by the judge in reaching his or her conclusions. That is certainly true in the recent case of Janak Shah (TC4706).

The actual decision – that the tribunal had no jurisdiction to consider the appeal – was unexceptional; the taxpayer was in reality complaining about his treatment by HMRC. However the judge’s comments make interesting reading. He struggled to make sense of the taxpayer’s statement of account. A flavour of his frustration can be seen in the following quote:

“It is not just Mr Shah who is confused by self-assessment statements. I am confused by them and [the officer who conducted HMRC’s case] agreed they were confusing at least in Mr Shah’s case where as I have mentioned there were 43 entries on the statement issued in June.”

I...