TC09537 - [2025] UKFTT 00597 (TC)

Case Number: TC09537

Llandudno Magistrates' Court

The Court House

Conwy Road

Llandudno

Appeal reference: TC/2019/04485

CAPITAL GAINS TAX - ENTREPENEURS RELIEF - Appellant did not satisfy Condition A, because not a director for 12 months prior to disposal of a share - Appeal dismissed

INCOME TAX - Whether inaccuracy in a self-assessment return? - Yes; sum declared as income received subject to PAYE regime was not so received, but treated as deduction to Director's Loan Account - Whether deliberate or careless? - Deliberate - Appeal dismissed

Judgment date: 29 May 2025

Before

TRIBUNAL JUDGE CHRISTOPHER MCNALL

TRIBUNAL MEMBER KERRY PEPPERELL

Between

MICHAEL WHINES

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Mr Michael Whines appeared in person.

For the Respondents: Mr Andrew Wilde, a litigator of HMRC Legal Group, Washington, Tyne and Wear

DECISION