Interesting ETL DA case re deliberate misconduct

That I note proves me right (albeit burden of proof re non-deliberate aspects shifts to taxpayer)

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On what seems to be a novel point (although Clark v. HMRC [2017] UKFTT 392 (TC) was not cited). (The same principle will of course apply re careless vs. non-careless errors.)

https://www.bailii.org/uk/cases/UKFTT/TC/2024/TC09191.html

Tribunal decides deliberate errors not infectious | AccountingWEB

https://www.accountingweb.co.uk/tax/personal-tax/tribunal-decides-delibe...

Naturally, HMRC disagreed with my view, and I'm a bit surprised that the taxpayer's advocate did not cite the above supporting cases mentioned by me, but all's well that ends well.

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By Ruddles
19th Jun 2024 14:57

Good for you. (Although no-one was arguing with you.)

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