LOSS OF TAX ATTRIBUTABLE TO ACCOUNTANT'S NEGLIGENCE IN ROTBERG FTT RULING

摘要

In the case of Rotberg v Revenue & Customs [2014] UKFTT 657(TC) Mrs Rotberg made three disposals of shares in two private companies (Jobsite Ltd and Auto Online Ltd) in 1999-000, 2000-01 and 2003-04, reinvesting the proceeds in subscriber shares in El Shaddai Business Development Ltd (El Shaddai). Prior to the disposal in 1999-2000, Rotberg's accountant (Mr Michell) telephoned HMRC and spoke to a Mr Hutchings, an inspector of taxes at a local compliance office, to ask whether roll-over relief would be available in respect of the sale and reinvestment, and based on the barest of facts Hutchings confirmed that roll-over relief would be available.