An appeal against a penalty for failing to take the necessary corrective action in response to a follower notice was allowed, as it was reasonable in all the circumstances for the taxpayer not to have taken the corrective action.

The appellant worked as an IT contractor. Some of his colleagues recommended tax consultants (Montpelier) to him. The appellant made checks about Montpelier and they appeared to him to be one of the top 50 UK accountancy companies. The appellant attended a presentation by Montpelier in 2004 and decided to utilise their tax planning services.

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