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Cataclysmic decline

07 July 2014
Issue: 4459 / Categories: Tax cases , time to pay , Admin , Compliance

R Campbell (TC3628)

The taxpayer was a 50% partner in a commercial estate agency which suffered financial difficulties because of a slump in the property market.

His adviser called HMRC on 20 January 2010 to say the taxpayer could not pay tax due on 31 January. The adviser suggested time-to-pay (TTP) arrangements to allow his client to pay the sum in £2 000 instalments over 28 months.

The Revenue said an inspector would have to agree the plan because it exceeded one year but the taxpayer should make the initial payment on account.

The taxpayer continued to make monthly payments but HMRC said a formal TTP arrangement did not exist. The department issued late payment surcharges against which the taxpayer appealed.

The First-tier Tribunal noted a conversation about the taxpayer’s inability to pay had taken place in January 2010 and led to the Revenue allowing an informal TTP accord.


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