The appellant was a member of a film partnership. In October 2014, HM Revenue and Customs (HMRC) informed the appellant that they would be issuing him with an accelerated partner payment notice (PPN) (pursuant to FA 2014, Sch 32, para 3) for the tax year 2004/05, and stated that the issue of a PPN would trigger an obligation to make an accelerated partner payment within 90 days.
The PPN for 2004/05 was sent on 14 November 2014, stating that payment was due on or before 17 February 2015, and warning that surcharges would apply for late payment. HMRC subsequently sent a PPN for 2005/06 on 28 November 2014, which also contained information on surcharges. On 10 February 2015, the appellant wrote to HMRC making representations against both PPNs. On 29 June 2015, HMRC wrote to the appellant confirming both PPNs without amendment.
On 8 July 2015, the appellant wrote to HMRC requesting a “review of your demand for
