An accelerated payment notice that specified two different payment amounts meant that a penalty for non-payment was unsustainable and the penalty was therefore cancelled.
On 23 July 2015, HM Revenue and Customs (HMRC) issued a purported accelerated payment notice (APN) for 2007/08, in connection with the appellant’s participation in the ‘Liberty 2’ tax avoidance scheme.
The APN stated at the start of the document: ‘Amount due in respect of this notice: £56,905.20’. However, in the body of the APN, it stated: ‘Amount due: £53,063.70’. HMRC received no response to the APN from the appellant, and on 5 November 2015, a penalty notice was issued for non-payment.
The appellant appealed against the penalty. The appellant’s grounds of appeal were originally that he had never received the APN, that there had been a miscalculation of the amount demanded,
