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The taxpayer was a partner in a firm of solicitors. The Special Commissioners had decided that there had been negligent conduct in the preparation of the partnership statements.
HMRC had amended the partnership statements so the firm appealed. An offer was made by the firm to settle the tax but on condition that HMRC did not seek penalties.
The department accepted the offer but said it was without prejudice to the determination of penalties.
HMRC then switched from addressing correspondence to the firm to writing to the taxpayer at the firm’s address.
The taxpayer paid the amount owing but HMRC later sought penalties under TMA 1970 s 95. The taxpayer challenged the penalty.
The Special Commissioner ruled that HMRC had the power to raise a penalty so the taxpayer appealed.
The High Court decided that switching the liability...
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