Conclusions
Conclusion
For the above reasons, the appeal is allowed.
Right to apply for permission to appeal
This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice.
Release date: 16th MAY 2025
- Heading
- Introduction
- Overview of the case
- The legislative scheme
- The case law on reasonable excuse
- The case law on special reduction
- Findings of fact
- The Appellant’s complaint to HMRC
- Penalty for late payment
- Reasonable excuse
- Discussion
- Special reduction
- HMRC’s arguments
- The Appellant’s arguments
- Discussion
- Conclusions
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