“The statute requires that the issue of reasonable excuse is considered before the determination is issued and not afterwards.”
"What, then is meant by “special circumstances”? Here we come to the crux of the case… In other words, to be special the event must be something out of the ordinary, something uncommon ; and that is the meaning of the words “special” in the context of this Act." (Emphasis added)
"53. …Plainly ["special circumstances"] must mean something different from, and wider than, reasonable excuse, for (i) if its meaning were confined within that of reasonable excuse, paragraph 9 would be otiose, and (ii) because paragraph 9 envisages a reduction in a penalty rather than absolution, it must be capable of encompassing circumstances in which there is some culpability for the default: where it is right that some part of the penalty should be borne by the taxpayer. 54. … They [i.e. special circumstances] must encompass the situation in which it would be significantly unfair to the taxpayer to bear the whole penalty." 63. The meaning of the expression "special circumstances", in the equivalent provisions of Schedule 24Finance Act 2007 , was also examined by the Tribunal in Collis v Revenue & Customs[2011] UKFTT 588 (TC) (Judge Berner and Mr Adams). The Tribunal said (at paragraph 40): "