Hogarth v HMRC [2019] WTLR 79

Wills & Trusts Law Reports | Spring 2019 #174

The appellants were trustees of a life interest trust, the income of which was mandated to the life tenant and passed directly to him. HMRC served a notice under s8A of the Taxes Management Act 1970 to file an income tax return on the trustees. When no return was filed, HMRC assessed penalties against the trustees for failure to file the return by the due date. The trustees appealed to the First-Tier Tribunal against the decision of HMRC to reject their appeals, arguing that they thought a return had been filed by their previous agents, that given that the return was a ...

Carrasco & anr v HMRC [2016] UKFTT 0731 (TC)

Wills & Trusts Law Reports | January/February 2017 #166

Mrs Carrasco inherited a London property known as 33 Smith Terrace, Chelsea in June 1988 (‘the property’). She subsequently vested the property in herself and her husband Javier Carrasco by way of a Deed of Gift.

The property was let to tenants from June 1998 to late June 2010. In 2010 it was put up for sale. Exchange of contracts took place on 25 May 2010, and completion took place on 23 July 2010. The appellants moved into the property on 29 June 2010 and resided there until 22 July 2010.

In April 2012, and upon professional advice, the appellants executed a p...