An appeal against penalties for non-compliance with an information notice was allowed due to the notice being vague and unlimited in point of time.
HM Revenue and Customs (HMRC) stated to the appellant that information was held indicating that he had traded as a financial adviser prior to January 2010, and sought information about it. The appellant did not reply, and HMRC issued an information notice to him (under FA 2008, Sch 36, para 1).
The information notice demanded: “Full details of your income as a financial advisor from the date you commenced to 31 December 2009; Details of payments made to workers from the date you commenced as a financial advisor to 31 December 2009; The names and addresses of any workers you engaged from when you commenced in business to 31 December 2009.” The appellant did not provide any information in response to the notice, and appealed to the First-tier Tribunal (FTT) after HMRC
