UT/2024/000093 - [2025] UKUT 00206 (TCC)

Case Number: UT/2024/000093

The Royal Courts of Justice,

Rolls Building, London

INCOME TAX – unauthorised payments from pension scheme – whether HMRC have power under section 29 Taxes Management Act 1970 to assess amounts chargeable to income tax under sections 208 and 209 Finance Act 1994 – yes – appeal dismissed

Judgment date: 26 June 2025

Before

JUDGE THOMAS SCOTT

JUDGE ASHLEY GREENBANK

Between

LARRY TRACHTENBERG

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Keith Gordon, instructed by Simmons Gainsford LLP

For the Respondents: Rebecca Murray, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs

DECISION