[2014] UKFTT 657 (TC)

Judge Roger Berner, Mrs Amanda Darley

Decision released 7 July 2014

Capital gains tax – Assessment made outside ordinary time limit – Taxes Management Act 1970 (‘TMA 1970’), s. 36(1) – Whether loss of capital gains tax attributable to negligent conduct of taxpayer or a person acting on her behalf.

Jurisdiction – Whether First-tier Tribunal has jurisdiction to consider legitimate expectation and other public law arguments – Construction of Taxes Management Act 1970 (‘TMA 1970’), s. 50(6).

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