Tax Appeals Commission determination 145TACD2025 regarding Income Tax, 2025

• Administrative Decision Number: 145TACD2025
• Year: 2025
• Date: 09 April 2025
• Respondent: REVENUE COMMISSIONERS

1

Between

Appellant

and

REVENUE COMMISSIONERS

Respondent

Determination

Introduction

1. This is an appeal to the Tax Appeals Commission (“the Commission”) on behalf of

(“the Appellant”) against assessments to income tax for the 2011 and

2012 tax years raised by the Revenue Commissioners (“the Respondent”).

2. In accordance with the provisions of sections 949U and 949AN of the Taxes

Consolidation Act 1997 (“TCA 1997”), this appeal is determined without a hearing.

Background

3. The Appellant was one of a large number of appellants who participated in one or more

of the Liberty Syndicates. The appeals are referred to in this determination as the Liberty

Syndicate appeals, or simply the Liberty appeals.

4. In December 2019, the Commission issued determinations in respect of 32 appeals

concerning the Liberty Syndicates. These determinations included 32TACD2020 and

53TACD2020. Commissioner Gallagher found against the appellants on all three grounds

of appeal, and determined that the assessments raised by the Respondent should stand.

145TACD2025