Claire Blenkin v The Commissioners for his Majesty’s Revenue and Customs
Decision date: 4 December 2025
Neutral citation: [2025] UKFTT 1508 (TC)
Overall AI summary confidence: medium
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: medium
This appeal concerned discovery assessments for 2018/19 and 2019/20 and related complaints by the appellant about HMRC's handling of other taxpayers, a data breach, and interest/another tax year. The Tribunal held it had no jurisdiction to decide complaints about HMRC's treatment of other taxpayers or the data-breach complaint and found the two discovery assessments were protected, correctly quantified and timely issued. Interest and the 2020/21 self-assessment were not appealable to the Tribunal. 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: medium
The Tribunal's dispositive reasoning is that it may only determine facts and apply the law to the individual taxpayer's case (so it cannot adjudicate on HMRC's treatment of other taxpayers or subsequent systemic complaints), and that where discovery assessments are properly characterised as protected assessments, they will be upheld if their quantification and timing are correct.
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 includes observations that administrative delay (including judicial long-term sick leave) can justify extensions of time for requesting full reasons and that, when a short decision has been given and a full decision is later required, a judge may rely on parties' written statements (such as HMRC's Statement of Reasons) if oral recollection is insufficient.
Warning
The chunk is repetitive and contains duplicated paragraphs and minor chronological inconsistencies, which made extraction of a concise narrative difficult. The notes are repetitive and contain duplicated paragraphs and minor chronological inconsistencies; they may be materially incomplete.