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Decision Number: |
TC 08434 |
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Appellant:
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EXCLUSIVE PROMOTIONS LIMITED
MARK FOX
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Respondent:
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Her Majesty's Revenue & Customs |
Chairmen / Special
Commissioners: |
ANNE REDSTON
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Date Of Decision:
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01/03/2022 |
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Main Category:
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PROCEDURE |
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Main Subcategory:
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Other |
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Notes:
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INCOME TAX AND NATIONAL INSURANCE – APNs – penalties and surcharges – lead cases for 500 appellants –HMRC failure to consider some or all of the representations made – whether this failure meant that the time limit for paying the APNs had not started to run, so that there could be no penalties or surcharges – HMRC change of position during hearing – position of other appellants – role of designated officer - whether appellants believed their judicial reviews would succeed because of failures by designated officer – whether believed no obligation to pay APNs because of interim relief – whether belief objectively reasonable |
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Decision(s) to Download:
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TC 08434.pdf 
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