The appellant filed an ATED return late, but the ATED return was not required, and the appellant had a reasonable excuse for late filing penalty purposes 

The appellant, a property investment company, was jointly owned by husband and wife. The appellant purchased its first property in 2016 and rented it out. On 11 January 2017, the appellant purchased for £265,000 a derelict pub, which had been abandoned for some five years. The purchase was financed by refinancing the first property. The refurbishment required was extensive. The material and labour costs amounted to £156,191 and the legal, architecture and planning fees amounted to £35,000, a total of £191,191. The property was rented out from approximately August 2019.

During 2019, the appellant changed accountants. In January 2021, in conversation with others, the husband discovered the existence of the annual tax on enveloped dwellings (ATED). He promptly investigated