A witness statement by an HM Revenue and Customs (HMRC) employee who was familiar with the computer procedures for issuing tax return notices and penalty notices was accepted as evidence that tax return and penalty notices were issued to the taxpayer. 
 
Background 
 
HMRC issued notices to file self-assessment returns for the tax years 2010/11, 2011/12, 2012/13 and 2014/15 to the appellant on 6 April 2011, 6 April 2012, 6 April 2013 and 6 April 2015 respectively. The appellant failed to file her self-assessment returns for those tax years by the due dates. HMRC issued a total of 13 late filing penalties (under FA 2009, s 55). The appellant appealed. 
 
The appellant submitted various grounds for appeal, which included: (1) HMRC had failed on the balance of probabilities to demonstrate that a notice to file was issued to her for each year; (2) HMRC failed to