This week's opinion

I have commented before about the fair way the First-tier Tribunal treats individual taxpayers when it is clear that they are in a muddle and are not trying to hoodwink the judge. But this depends on the case getting to the stage at which the judge can hear the argument.

There is an increasing trend of cases where the taxpayer or their agent have failed to understand the process and have lost the opportunity to make the arguments. Reed (TC5396) is a good example.

The tribunal issued clear directions as to which documents and information were required before the substantive hearing and these were not complied with. A second chance was given and compliance was again limited. There seems to have been an assumption that the tribunal would hear the arguments if the taxpayer turned up regardless of whether the required information had been provided. This was not the case and...