Kevin Read examines the appeal rights within partnerships.
The ‘nominated partner’ of a partnership is responsible for:
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filing the partnership tax return;
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dealing with matters arising from an enquiry; and
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keeping the other partners informed of the progress of any enquiry.
Crucially (for the other partners), any appeal rights relating to the partnership are conferred only on the nominated partner.
Kelly v HMRC
In Kelly v HMRC [2025] UKFTT 852 (TC), Michael Kelly [MK] was a member of a film partnership (‘Invicta’), income from which was included in his self-assessment tax returns (SATRs).
HMRC issued closure notices to Invicta, with a consequential