Sheiling Properties Ltd v The Commissioners for HM Revenue and Customs: [2020] UKUT 0175 (TCC)
Upper Tribunal Tax and Chancery decision of Mr Justice Trower and Judge Thomas Scott on 8 June 2020.
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INCOME TAX 鈥� penalty for non-payment of accelerated payment notice 鈥� is tax demanded under a Regulation 80 PAYE determination 鈥渄isputed tax鈥� within APN provisions 鈥� yes 鈥� did taxpayer have a reasonable excuse for non-payment of penalty 鈥� no 鈥� circumstances in which belief that APN was procedurally invalid could constitute reasonable excuse 鈥� appeal dismissed.