The appellant filed his tax return for 2011/12 by 31 January 2013, but his income tax liability was not paid in full until 24 October 2013. HM Revenue and Customs (HMRC) imposed late payment penalties (under FA 2009, Sch 56, para 1). The appellant appealed, on the basis that he had a reasonable excuse for the late payment.
The tax liability had arisen because in April 2011 the appellant sold shares in a company he had worked for. In May 2011, the appellant and his wife bought a house using proceeds from the share sale. The appellant said that he intended to raise funds by way of a mortgage on the property after moving in, in order to pay his tax by the due date of 31 January 2013.
However, in March 2012 the appellant and his wife separated, and his wife started divorce proceedings. The appellant wanted to sell or mortgage the property in order to pay his tax liability, but his wife's solicitor arranged for a matrimonial
