Usher [2016] UKFTT 050 (TC)
Wills & Trusts Law Reports | May 2016 #159The appellants were the executors of the will of the deceased who had died on 15 October 2012. The appellants had filed an annual self-assessment return for 2012/13, covering the period from 6 April 2012 to the date of death, which under-declared the income for that period. On 26 September 2013, an executor had written to HMRC, sending a cheque for the outstanding tax then due and stating that he presumed that this was full and final settlement and would proceed to distribute the estate. The executors proceeded to do that but failed to publish notice in the London Gazette of tha...
Litman & anr v HMRC [2014] UKFTT 089 (TC)
Wills & Trusts Law Reports | June 2015 #150This was the conjoined appeal of two taxpayers against penalty determinations issued against them by HMRC. The taxpayers, who were both business people who held directorships in a number of UK companies, had realised capital gains on the disposal of an entity known as Efforsenrab Ltd and land and buildings in Essex in the UK. They participated in a capital redemption policy scheme and claimed a capital loss arising from that scheme to be set against the capital gains which they had realised. They both signed a professional services agreement with a tax adviser under which it agreed to pr...