Ms A Z v Commissioners for Her Majesty's Revenue and Customs
Decision date: 5 May 2010
Neutral citation: [2010] UKFTT 225 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
This case records appeals by Ms A Z against late filing penalties and late payment surcharges for a series of tax years. The First-tier Tribunal quashed the late filing penalty for 2002–03 and quashed late payment surcharges for 2002–03, 2003–04, 2005–06 and 2008–09, while dismissing the appeal against the late filing penalty for 2007–08 and upholding surcharges for 2006–07 and 2007–08. The decision includes full written reasons, an appendix of return dates, liabilities and surcharge amounts, and procedural directions on appeals to the Upper Tribunal.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: high
From the tribunal’s determinations: appeals against late filing penalties and late payment surcharges may be resolved on a year-by-year basis according to the facts and law applicable to each year, and an application for permission to appeal to the Upper Tribunal must be made in writing, received within 56 days of service of full written reasons, and must identify the decision, the alleged errors and the result sought.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The appendix of turnover, profit, liabilities, surcharge amounts and payment dates is treated as supporting factual material rather than establishing any standalone legal rule; repetition and form of the appendix are administrative/explanatory observations of the tribunal.
Warning
Chunk contains repeated passages and formatting artefacts; some data are tabulated and presented with duplication. Notes contain repeated passages, formatting artefacts and tabulated data; they may be noisy and materially incomplete.