The failure by a company to pay National Insurance contributions liabilities was attributable to neglect on the part of its director, whose appeal against a personal liability notice served on him was therefore dismissed. 

On 8 February 2019, HM Revenue and Customs (HMRC) opened an enquiry into the appellant’s company, the purpose of which was to investigate the circumstances and to establish the facts concerning the failure of the company to pay National Insurance contributions (NICs) due to HMRC. During the period in dispute (6 August 2016 to 5 June 2018), the appellant was the sole director. On 11 December 2019, HMRC wrote to advise that a formal decision had been made to issue a personal liability notice (PLN), giving details of how the decision had been reached and enclosed a PLN requesting payment of £103,420. The appellant appealed. 

The First-tier Tribunal (FTT) considered relevant case law. The FTT also stated that the appellant