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K O’Donnell (TC5471)
Reasonable excuse for failing to make an accelerated payment on time
HMRC issued the taxpayer two accelerated partner payment notices (PPNs) in relation to tax for 2004-05 and 2005-06. He queried the notices saying they related to losses arising from his participation in film partnerships that were carried back and set off against income in 2001-02 and 2002-03. He argued that because HMRC had an enquiry open for his 2004-05 and 2005-06 tax returns only and had not opened one into the claim to carry back the losses under TMA 1970 Sch 1A it was out of time to assess him for 2001-02 and 2002-03.
In June 2015 HMRC confirmed the PPNs. In September it issued penalties for the non-payment of the notices within the deadline against which the taxpayer appealed.
The issue was whether the taxpayer had a reasonable excuse for the late...
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