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First-tier Tribunal (Tax)
You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> Faulkner v Revenue & Customs (INCOME TAX/CORPORATION TAX : Losses) [2018] UKFTT 270 (TC) (16 May 2018)
URL: http://www.bailii.org/uk/cases/UKFTT/TC/2018/TC06500.html
Cite as: [2018] UKFTT 270 (TC), [2018] STI 1730, [2018] SFTD 1224
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| Decision Number: | TC 06500 |
| Appellant: | Mr Gavin Faulkner |
| Respondent: | The Commissioners For Her Majesty's Revenue & Customs |
|
Chairmen / Special Commissioners: |
Richard THOMAS |
| Date Of Decision: | 16/05/2018 |
| Main Category: | INCOME TAX/CORPORATION TAX |
| Main Subcategory: | Losses |
| Notes: | INCOME TAX - claim to carry back trading loss of LLP attributable to partner to previous tax year - whether claim in return out of time: yes - whether appealable decision: no, Raftopoulou followed whether in time claim made outside return - whether failure by HMRC to give effect to claim appealable - effect of carry back claim on tax, penalties and surcharges of earlier year. INCOME TAX - appeals against penalties under s 93 TMA and Schedule 55 FA 2009 - appeals against surcharges under s 59C TMA - whether permission should be given to make late appeals to HMRC - whether appeals notified to Tribunal late: NT ADA Ltd (Upper Tribunal) considered - appeals allowed in part |