Carelessness over a tax matter can arise both from the taxpayer or the tax advisor, writes Elliot Green Many taxpayers make use of the services of a tax advisor to complete their tax returns.
The case of Callen v Commissioners for HMRC [2022] ULFTT 00040 (TC) involved an assessment of HMRC tax carelessness in relation to the completion of a personal tax return. The taxpayer, Jason Callen, had employed an accountant, Mr Bevis, to assist him with his tax return. Mr Callen was a derivatives trader.
He had become involved in a tax avoidance scheme. The scheme was known as the Montpelier Section 730 Dividend Strip Scheme (“the Scheme”) in which it sought to set off losses against Mr Callen’s income in the tax year 2008-2009.
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