Francis Uzoh v The Commissioners for HMRC

Decision date: 5 February 2026

Neutral citation: [2026] UKFTT 231 (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 four discovery assessments issued by HMRC for tax years 2017/18, 2019/20, 2020/21 and 2021/22 arising from business travel/subsistence claims submitted via the Tommy's Tax app. The First-tier Tribunal found the appellant failed to prove the expense claims were allowable and that HMRC made valid discovery assessments; it also found the appellant’s reliance on an adviser amounted to carelessness. The appeal was dismissed and the assessments upheld.

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 held that (1) an officer’s discovery under s29 TMA requires both a subjective belief by the officer and an objective test that a reasonable officer could have formed that belief on the available information; and (2) a taxpayer who relies wholly on an adviser can nevertheless be liable for carelessness where, in the circumstances, a reasonable taxpayer would have taken additional simple steps to verify entitlement to the claimed deductions.

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 observed that whether reliance on an adviser negates carelessness depends on the specific facts and does not create a general rule absolving taxpayers of responsibility. It also noted HMRC had not compared the appellant’s early-2024 supporting evidence to the claimed figures, but that did not persuade the tribunal the claims were proved on the balance of probabilities.

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