Madana Saibo Mohamed Hakeem v The Commissioners for HMRC
Decision date: 19 May 2026
Neutral citation: [2026] UKFTT 744 (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
Mr Hakeem appealed penalties for failing to notify rental income for tax years to 2017–2020, arguing reliance on a friend's incorrect advice and financial hardship. The Tribunal applied the reasonable-excuse test, found his reliance on informal unverified advice and his lack of funds did not constitute a reasonable excuse, dismissed the appeal, and corrected the penalty calculation under s.50(7) TMA, increasing it from £1,153.84 to £1,174.54.
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 held that reliance on informal, unqualified advice without verification is not objectively reasonable and therefore does not constitute a reasonable excuse for failing to notify tax liability; likewise, mere inability to pay does not, by itself, excuse a failure to notify under Sch 41 para 20(2).
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 Tribunal reiterated the stepwise approach from Christine Perrin for assessing reasonable excuse, noting the need to consider the taxpayer’s attributes and circumstances and that ignorance of the law can sometimes amount to a reasonable excuse depending on its cause, with the burden of proof resting on the taxpayer.
Warning
The chunk contains substantial repetition of the same material. Notes contain substantial repetition and may omit full detail of the judgment.