TC09512 - [2025] UKFTT 00522 (TC)

It was contended that the assistance given in establishing the tax due warranted a greater level of mitigation than had been provided. Particularly for NN who had been demonstrated to have been unwell in the 2018. It was accepted that some of the appendices to the disclosure report remained outstanding, but it was asserted that they did not impact on the tax calculations as the missing appendices predominantly concerned rental income which represented only 7.45% of the total assessments. The Appellant proposed penalties at 35% for commission income and 45% for rental income