The appellant was originally assessed to VAT for periods 9/13 to 3/16 totalling £102,168. This was reduced on review to VAT for periods 3/15 to 3/16 totalling £46,440. The reduction was on the basis that the amounts assessed for the periods 9/13 to 12/14 were out of time, and were therefore cancelled.
Background
The appellant was a sole trader who was engaged in the supply of vehicle repairs and haulier services. It is a matter of dispute when he ceased to trade.
There was a joint enquiry into both income tax and VAT liabilities of the appellant. For the periods 12/13 to 9/16, the appellant had filed “nil” returns.
Several attempts had been made between September 2013 and June 2014 by various HMRC officers to arrange a meeting with the appellant, but all appointments made to meet him were cancelled. On 9 July 2015, HMRC wrote to the 
