Neglect or negligent conduct
Assessment of amounts due by way of penalty
Generally
Time limits and supplementary assessments
Claim statute-barred
Company buyback scheme, compensation for negligent advice
Compensation, capital or trading receipt
Costs
Domicile status of client
Income tax self-assessment return, undisclosed profits
Incorrect information, penalties
Loss of tax due to
National Insurance contributions, non-payment by limited company
Partnership records
Penalties
Mitigation
Restriction of deductions for direct tax purposes
Penalties for
Penalties for offences
Relevance of concept re careless conduct
Returns and accounts, penalties
Failure of appeal against amount
Generally
Maximum award not excessive
Reduction of maximum penalties
Tax advice
Claimant resident but not ordinarily resident in UK for tax purposes
Company buyback scheme
Generally
Tax avoidance scheme, clearance revoked
