The First-tier Tribunal sided entirely with HMRC (barring one administrative matter) in confirming the quantum of penalties imposed by HMRC for a wide range of tax failures – Dowds v HMRC  UKFTT 402 (TC).
The FTT did not accept that the failures could be described as “inadvertent” or “careless”:
“In our view, the frequency with which the relevant inaccuracies occurred, the length of time over which they occurred and the quantum of the amounts involved make it inconceivable that the inaccuracies were inadvertent or careless.”
The FTT did not agree that any larger abatement should have been made. There were no credible explanations for the inaccuracies. Three of the four grounds for appeal had no relevance to disclosure and cooperation, and the fourth ground (ill health) did not justify any additional abatement. The FTT would not have given even the 5% abatement for seriousness, but declined to exercise its discretion to increase the penalty.