It was not reasonable for the appellant in his circumstances to have been ignorant of the requirement for him to file a tax return for 2020/21 having made no enquiries about his legal obligations as a non-UK resident landlord and having failed to notify HMRC of any change of circumstances; his ignorance of the law was not a reasonable excuse. 

The appellant’s tax return for 2020/21 was received by HM Revenue and Customs (HMRC) on 10 February 2023, which was 375 days late. HMRC issued late filing penalties amounting to £1,600. The appellant appealed. He argued that he had a reasonable excuse for filing the return late on the following grounds: (1) He thought that because he was living abroad and had no tax liability for 2020/21, he was not required to file a tax return; (2) He was abroad and unreachable due to the lack of internet abroad. Consequently, he had been unable to see or open any of his letters and was unaware of the penalties and