Following his first return HMRC arranged for a VAT visit to review the Appellants records in relation to a repayment claim. During the visit, the Appellant raised the subject of the VAT, incurred on the helicopter pilot training that he had undertaken in the period more than 6 months prior to registering for VAT. He explained to the visiting officer that he had not included this in his claim for that period; the reason was that he was not sure whether the input tax could be claimed as it related to obtaining a private licence, but it was necessary for his business.  The Appellant was told that a claim would be out of time. 

The Appellant was not happy with this advice as he was aware that other people had received their input tax back. The Appellant said that he would include this input tax in his next return, even though he was told of the voluntary disclosure procedures.

Following the submission of the return HMRC