Steven Hague v The Commissioners for HM Revenue and Customs [2024] UKUT 00436 (TCC)
Upper Tribunal Tax and Chancery Decision of Judge Rupert Jones on 20 December 2024
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The Applicant, Mr Steven Hague, applies to the Upper Tribunal (Tax and Chancery) (바카라 사이트淯T바카라 사이트�) for permission to appeal the decision of the First-tier Tribunal (Tax Chamber) (바카라 사이트渢he FTT바카라 사이트�), released on 19 February 2024 (바카라 사이트渢he Decision바카라 사이트�). The appeal was decided by the FTT following a hearing conducted on 12 May 2023. 2. The FTT dismissed the Applicant바카라 사이트檚 appeal against the following decisions of HMRC: a) nine assessments (바카라 사이트楧iscovery Assessments바카라 사이트�) issued by the respondents (바카라 사이트楬MRC바카라 사이트�) pursuant to s 29 of the Taxes Management Act 1970 (바카라 사이트楾MA바카라 사이트�) for the nine consecutive tax years from 2007-08 to 2015-16 in respect of unpaid income tax and capital gains tax. For the purposes of the appeal, the total of the nine discovery assessments stood at 拢67,177.01. b) nine penalty assessments (the 바카라 사이트楶enalties바카라 사이트�) for failure to notify the relevant tax liabilities for the said years. The penalties were raised pursuant to section 7 of TMA (for the years 2007-08 and 2008-09), and Schedule 41 to the Finance Act 2008 (바카라 사이트楽ch 41바카라 사이트�) (for the years 2009-10 to 2015-16). The overall quantum of penalties for the nine years was 拢43,665.06.