Mariner v HMRC [2013] UKFTT 657 (TC)

March 2014 #137

Income tax;careless or negligent completion of income tax return;reliance on a professional advisor;reasonable excuse for careless or negligent completion of return.

Elizabeth Mariner (the appellant) instructed a professional tax advisor to complete and file her 2011 income tax return with HMRC. She was making losses on a let property. The return set these losses against her income from other sources. HMRC did not accept that the losses could be ‘set-off’ in this way. A penalty for underpaid tax as the result of the careless or negligent completion...