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Man versus machine
Readers of Taxation may well have missed it among the new year festivities but at the very end of 2019 a decision of the Upper Tribunal was released that could have interesting implications for those seeking to appeal late filing penalties.
The case in question is CRC v Nigel Rogers and Craig Shaw [2019] UKUT 0406 (TCC) (tinyurl.com/yxxabpgf) – an appeal by HMRC against two earlier decisions of the First-tier Tribunal on the thorny issue of whether a notice to file a self-assessment return has to be issued by an actual HMRC officer to be valid.
As well as giving a clear (and binding) ruling on this issue the Upper Tribunal decision also contains some interesting comments on the jurisdiction of the lower tribunal and provides guidance that can be applied in future cases concerning TMA 1970 s 8...
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