A penalty for non-compliance with an information notice was issued later than the statutory deadline, andâ¯HMRC could not refresh the time limit simply by reissuing the notice and repeating the information requirements.â¯
On 24 July 2017, HM Revenue and Customs (HMRC) wrote to the appellant, stating they had received information that the appellant had “purchased and disposed of a number of properties going back over a number of years” and failed to declare them.â¯No response was received. On 11 October 2017, HMRC issued the appellant with a notice (under FA 2008, Sch 36) (Notice 1) requiring him to produce various information and documents by 20 November 2017.
On 30 July 2018, HMRC sent a second information notice (Notice 2) to the
