Cases generated by artificial intelligence

The taxpayer sold a property which she had rented out but failed to notify her liability to capital gains tax. HMRC issued a penalty against which the taxpayer appealed. She said she had reasonable excuse because of her mental health condition and because it was reasonable for her to be ignorant of the law.

The First-tier Tribunal decided that the taxpayer’s mental health did not provide a reasonable excuse. It had not prevented her putting the property on the market and liaising with her solicitor. She had managed to calculate the approximate capital gain and made an investment. She also dealt with lodgers at her own home. The tribunal therefore considered that a ‘reasonable person’ in the taxpayer’s position would have contacted HMRC to report the disposal and capital gains tax liability.

On ignorance of the law the judges again found this not to be a reasonable excuse. They said...