An appeal against daily penalties for the late filing of the appellant’s tax return was allowed, as HMRC had failed to prove that a notice specifying the date from which the penalties were payable had been given to him, and a ‘generic’ witness statement given by an HMRC officer concerning penalty procedures was found not to be admissible.
Summary
An appeal against daily penalties for the late filing of the appellant’s tax return was allowed, as HMRC had failed to prove that a notice specifying the date from which the penalties were payable had been given to him (as required by FA 2009, Sch 55, para 4(1)(c)), and a ‘generic’ witness statement given by an HMRC officer concerning penalty procedures was found not to be admissible.
Background
On 6 April 2012, the appellant was issued with a notice to file his self-assessment
