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In Michael Breen v HMRC [2022] TC08482, the First Tier Tribunal (FTT) dismissed an appeal against late filing penalties finding that a debilitating fear of making a mistake was not a reasonable excuse for the late filing of tax returns.

The FTT dismissed the penalty appeal finding that the taxpayer did not have a reasonable excuse as:

Useful guides on this topic

Adviser's Tax Penalty Planner
A guide to the key direct and indirect tax penalty regimes for returns and payments, excluding VAT.

Grounds for Appeal: Reasonable excuse
What is considered to be a 'reasonable excuse' when a taxpayer makes an appeal against a tax compliance failure?

How to appeal a tax penalty
What are the steps in making an appeal? What should your appeal cover? What does recent case law say on this topic?

Non-domicile status, deemed domicile & tax
Who is non-UK domiciled? What does this mean for UK Income Tax, Capital Gains Tax and Inheritance Tax? What reliefs are available to non-doms?

Sch 36 Information Notices
What is a Schedule 36 Information Notice? When can HMRC issue one? What rights does the taxpayer have when an information notice is issued?

External links

Michael Breen v HMRC [2022] TC08482


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