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INCOME TAX - High Income Child Benefit Charge - liability for the charge - yes - appeal against charge dismissed - penalties for failure to notify �no reasonable excuse no special circumstances - appeal against penalties dismissed
For the Respondents: �� Ms Maria Serdari litigator of HM Revenue and Customs' Solicitor's Office
             This appeal concerns the High Income Child Benefit Charge (" HICBC "). The appellant has been assessed (" the assessments ") to HICBC for the tax years 2017/2018 to 2019/2020, together with penalties (" the penalties ") for failing to notify chargeability under section 7 Taxes Management Act 1970 (" TMA "). The penalties have been assessed (" the penalty assessments ") pursuant to Schedule 41 Finance Act 2008 (" Schedule 41 "). The assessments amount in total to �2,248. The penalty assessments are for �604.08.
             There was no dispute between the parties as to the relevant legislation which we summarise below.
             By section 681B Income Tax (Earnings and Pensions) Act 2003 (which was inserted by Finance Act 2012 with effect for child benefit payments made after 7 January 2013) a person is liable to a charge to income tax, the HICBC, for a tax year if:
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