(1) The Executors of David Harrison (Deceased) and (2) Simon Harrison v The Commissioners for HM Revenue and Customs [2021] UKUT 0273 (TCC)

JurisdictionUK Non-devolved
JudgeJudge Jonathan Richards,Judge Ashley Greenbank
Neutral Citation[2021] UKUT 0273 (TCC)
Subject Matter5 November 2021
CourtUpper Tribunal (Tax and Chancery Chamber)
Published date08 November 2021
[2021] UKUT 0273 (TCC)
Appeal number: UT/2020/000388
INCOME TAX whether FTT had power to review HMRC’s refusal to exercise
discretion to accept taxpayers’ late elections for fixed protection no taxpayers’
appeals dismissed
UPPER TRIBUNAL
(TAX AND CHANCERY CHAMBER)
(1) THE EXECUTORS OF DAVID HARRISON (DECEASED)
(2) SIMON HARRISON
Appellants
-and-
THE COMMISSIONERS FOR HER MAJESTY’S
REVENUE AND CUSTOMS
Respondents
Sitting in public at The Royal Courts of Justice, Strand, London on 27 October 2021
Michael Collins, instructed by Independent Tax and Forensic Services LLP, for the
Appellants
Charles Bradley, instructed by the General Counsel and Solicitor for Her Majesty’s
Revenue & Customs for the Respondents
© CROWN COPYRIGHT 2021
TRIBUNAL:
JUDGE JONATHAN RICHARDS
JUDGE ASHLEY GREENBANK

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