Decision Number: | TC09033 |
Appellant: | PAUL JUDD |
Respondent: | His Majesty's Revenue & Customs |
Chairmen / Special Commissioners: |
Zachary CITRON |
Date Of Decision: | 03/01/2024 |
Main Category: | PROCEDURE |
Main Subcategory: | Other |
Notes: | VALUE ADDED TAX - Schedule 24 FA 2007 penalties for inaccuracies in VAT returns - personal liability notice given to director at time of alleged VAT return inaccuracies - company-s appeal against VAT assessments unsuccessful at First-tier Tribunal, Upper Tribunal and Court of Appeal - company in liquidation by time of litigation against assessments - application by appellant to amend grounds of appeal against PLN so as to argue that VAT returns not inaccurate - objection to application on basis that it was abuse of process, given outcome of company litigation - key issue: was there sufficient identification between company and appellant, so as to -fix- appellant with outcome of company litigation? - Held (on facts): yes - application for that new ground refused - application permitted as regards other grounds (-deliberate- inaccuracy and -attribution- to then-director) |