HMRC was not bound to allocate tax payments in a particular way where the taxpayer had made no particular allocation of her payments.
The appellant, a self-employed doctor, received from HM Revenue and Customs (HMRC) penalty notices for the late filing of tax returns, and late payment surcharges and penalties, for various tax years. The appellant appealed.
The appellant argued (among other things) that HMRC had not appropriately allocated payments of tax that she made, and that this resulted in an increase in the amount of late payment penalties and surcharges.
The First-tier Tribunal (FTT) found that when the appellant made her various tax payments, she did not request any of those payments to be allocated to her tax liability for any particular tax year. In the absence of such allocation, it was necessary to determine which payments should be allocated to which tax years’ liabilities, as this was
