Lindsay Hackett v The Commissioners for HMRC

Decision date: 2 October 2026

Neutral citation: [2026] UKFTT 1378 (TC)

Overall AI summary confidence: high

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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 appeal challenged 17 Personal Liability Notices issued to Mr Lindsay Hackett under paragraph 19 of Schedule 24 following Schedule 24 penalties assessed on his company Intekx for inaccurate VAT returns. The Tribunal found HMRC proved the company’s return inaccuracies for July 2009–October 2012 were deliberate (several periods were deliberate and concealed), that those deliberate inaccuracies were attributable to Mr Hackett as sole director, and that the PLNs were valid and correctly reflected the penalties; the appeal was dismissed.

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

The Tribunal’s dispositive reasoning is that where a company’s sole director directs and controls the company’s trading and VAT submissions, the company’s knowledge and conduct can be attributed to that officer for paragraph 19 purposes; and that deliberate inaccuracy (including deliberate concealment) can be inferred from a cumulative pattern of conduct — such as timing of logistics changes, refusal to provide requested records and non-retention of identifying information — rather than any single feature.

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 judgment observes (non-bindingly) that contemporaneous documentary evidence is particularly persuasive in long-running historical disputes; that untested witness statements have limited weight where the witness declines cross-examination; that non-use of HMRC verification services or reliance on commercial checks is not decisive alone but is part of the overall evidential picture; and that a tribunal may proceed under its procedural rules (Rule 33) where a party elects not to continue participating after reasonable adjustments.