Summary
The Upper Tribunal (UT) imposed penalties of 100% of the tax considered to be at risk (i.e. almost £1.25 million) as a result of an individual failing to comply with information notices issued by HM Revenue and Customs (HMRC).
Background
HMRC applied to the UT for the imposition of tax related penalties on an individual (under FA 2008, Sch 36, para 50) for failing to comply with information notices. The individual was a respondent both in his own capacity and separately as a personal representative.
The individual, an eminent barrister, submitted his personal tax returns for 2008/09, 2009/10 and 2010/11 in April 2012. HMRC opened an enquiry into those returns, and subsequently issued an information notice (under FA 2008, Sch 36, para 1(1)). The taxpayer only partially complied with the notice, and HMRC issued a fixed penalty of £300. HMRC
