The appellants jointly purchased a property. The stamp duty land tax (SDLT) return was subject to an enquiry by HM Revenue and Customs (HMRC), which resulted in SDLT of £30,550 being paid. HMRC also considered that a penalty was due for deliberate inaccuracy, and informed the appellants that their details may be subject to publication under the ‘deliberate defaulters’ provisions (FA 2009, s 94).
The appellants did not consider that they had deliberately evaded tax, and objected to the threat of their details being published, but subsequently paid HMRC’s penalty assessments. HMRC wrote to the appellants stating that their appeal against the penalty assessments was now settled by agreement (see footnote below).
Subsequently, HMRC notified the appellants that they were considering the publication of their names, and invited representations as to why this should not happen. The appellants’ reply
