The taxpayer's appeal against HMRC's refusal of a late appeal against penalties for the late submission of a self-assessment return was dismissed, as the relevant tax return and the penalty appeals were submitted several years late. 

The appellant's self-assessment return for the tax year 2010/11 was received by HM Revenue and Customs (HMRC) on 19 March 2019. HMRC issued late filing penalties, which initially amounted to £1,300 but were subsequently reduced to £400. The appellant appealed, which was received by HMRC on 5 September 2019. The appeal did not include an application for an extension of time to be allowed to make a late appeal.

HMRC considered whether the appellant had a reasonable excuse for the delay in appealing. The appellant's appeal was 1,842 days late against the £100 fixed penalty and 1,660 days late in respect of the £900 penalty and the £300 penalty. Having considered the late