Information notices requesting documents and information stretching back 20 years were varied to a six-year period and daily penalties for non-compliance with the information notices were reduced in the circumstances.
On 8 November 2016, following an informal request, HM Revenue and Customs (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’.
On 27 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
