The WLR Daily case summaries
[2023] WLR(D) 246
Court of Appeal
Archer v Revenue and Customs Comrs
[2023] EWCA Civ 626
2023 April 25, 26; June 7
Whipple, Falk, Simler LJJ
Revenue— Income tax— Assessment— Revenue issuing closure notices following enquiry into taxpayer's self-assessment tax return— Revenue issuing surcharge notices following non-payment of closure notices— Taxpayer contending notices ineffectual whilst judicial review proceedings extant— Whether taxpayer having reasonable excuse for non-payment— Whether subjective evidence required to support reasonable excuse—
Taxes Management Act 1970
, ss 59C, 118(2)