Tax Law · Upper Tribunal (Tax and Chancery Chamber)
Thomas Hanlon v The Commissioners for HMRC
Checked against the judgment on 7 October 2026 · how we verify
Facts
Mr Hanlon was a director of Cardiff Cash & Carry Ltd. HMRC issued the company a penalty of £242,243 under section 60 of the Value Added Taxes Act 1994 for failing to file VAT returns while knowing it was liable to pay VAT, and decided to make Mr Hanlon liable for the whole of that amount as a director. The First-tier Tribunal (Tax Chamber), after hearing evidence from Mr Hanlon, who was represented, and from three HMRC officers, dismissed his appeal. It found his behaviour dishonest, the penalty attributable to that dishonest conduct, and the full amount payable by him. The decision was released on 27 February 2024. Mr Hanlon applied to the FTT for permission to appeal on 30 January 2025, and explained that he had not known the decision had been released and had been poorly represented. On 12 February 2026 the FTT refused to admit the application out of time. Mr Hanlon applied in time to the Upper Tribunal on 26 February 2026, and Judge Zaman refused to admit that application on 14 May 2026. Mr Hanlon sought reconsideration at a hearing on 23 September 2026, which he attended, as did Mr Holt, who had appeared for HMRC before the FTT.
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