The Upper Tribunal (UT) dismissed a barrister’s appeal against penalties for late tax payments and held that the First-tier Tribunal’s (FTT’s) decision that he did not have a reasonable excuse for those late payments was within the range of reasonable conclusions open to it.
Background
The appellant had been in professional practice as a barrister for many years. His tax returns disclosed six-figure earnings, which fluctuated from year to year, but for the accounting year ended 30 April 2012 was £290,000. The tax on those earnings would have been due in January 2014. However, the appellant had encountered exceptional financial circumstances in 2012 to 2014.
In 2010, he had concluded a divorce settlement with a large lump sum and annual maintenance, but in 2012 he agreed on a clean break with his ex-wife involving the payment of a