In November 2016, following an informal request, HMRC sent a letter to the appellant headed ‘Notice to produce documents’, attaching a schedule headed ‘schedule of information and documents needed to carry out our check’.
In October 2017, again following an informal request, HMRC sent another letter to the appellant enclosing a second schedule setting out a different list of information and documents required.â¯
The first notice stated the appellant must let HMRC have the ‘documents’ requested by 8 December 2016 (i.e. within one month). The second notice said that the ‘documents’ requested in that letter must be given to HMRC by 27 November 2017.
Some of the information and documents were provided within the period specified in the notices, but not all. HMRC imposed an initial penalty of £300 and daily penalties in respect of each notice. The appellant
