Inaccuracies in tax return were not deliberate

The taxpayer was made redundant by MS in July 2016. He later began employment with another business. In his 2016-17 tax return filed in December 2017 he omitted about £176 700 of income received from MS in the period December 2016 to February 2017 - after he had left employment with that firm. The return also omitted any reference to MS having written off a loan of £143 420. The issue in dispute in was whether those omissions were deliberate.

HMRC said the omission was unlikely to be accidental because it was a significant sum. Further his settlement agreement with MS provided that he was liable to income tax on the settlement sums and he took legal advice before signing it. HMRC said that the taxpayer could have taken advice to ensure his return was accurate but chose not to.

The First-tier Tribunal noted that the taxpayer conceded his 2016-17...