UT (Tax & Chancery) UT-2024-000010 - [2024] UKUT 00416 (TCC)

Mr Cherry submitted that the Decision Notice relating to the Applicant reveals that she is in parlous financial circumstances insofar it has a reduced penalty on the grounds that she would suffer serious financial hardship if the financial penalty was larger. The proposed financial penalty is assessed as a level 4 seriousness matter in the Decision Notice. This indicates that the Authority considers the findings in its notice to be very serious.

As with the above submissions, that determination is premised on the outcome of the Grant Thornton file review process and the input and calculations of Dr Purdon which is based on that Grant Thornton file review process. For the reasons above this is an unsafe observation to be published in the Applicant’s Decision Notice and one which will not be apparent from a broad observation that the findings in the notice are preliminary and subject to challenge.