A detailed chronological analysis of a director’s loan account was reasonably required by HMRC for the purposes of an enquiry into a company tax return and there was no reasonable excuse for failing to provide that information.  
 
On 10 August 2017, HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s corporation tax self-assessment return for the period ended 28 February 2016. HMRC requested a number of items of information including the appellant’s bank statements and ‘a copy of the DLA [directors’ loan account], showing dates, amounts and descriptions of each transaction, for each director’. 
 
On 20 September 2017, HMRC issued an information notice (under FA 2008, Sch 36), repeating its request for the detailed DLA. On 27 September 2017, information was collected by HMRC from the appellant’s offices, including a copy of a directors’ loan