Upper Tribunal Tax and Chancery Chamber

UT/2022/000131 - [2025] UKUT 00063 (TCC)

Fecha: 04-Nov-2024

Introduction

Introduction

This is an appeal against a decision of the First-tier Tribunal which dismissed Mr Rafferty’s appeals against:

(a)

a closure notice for the year ended 2014/15;

(b)

discovery assessments for the years 2001/02 to 2013/14, and 2015/16 to 2016/17;

(c)

penalty determinations for the years 2001/02 to 2008/09, and penalty assessments for 2009/10 to 2011/12, and 2012/13 to 2016/17; and

(d)

A penalty issued under Schedule 36 of FA 2008 for failure to comply with an information notice.

Mr Quinn represented Mr Rafferty, and had represented Mr Rafferty at the hearing before the FTT. Ms Sheldon represented HMRC before us, but she had not appeared before the FTT.

Heading
Introduction
The Background
Judge Jones also granted permission to appeal on the following additional new grounds
Absence of cross-examination of Mr Rafferty
Ground 1 - One or two households
Ground 2 – Discovery assessments
Ground 3 – penalties for deliberate conduct
Conclusions