The taxpayer’s lack of funds resulting from the terms of a share sale agreement did not constitute a reasonable excuse, and the taxpayer could not escape the consequences of the apparent negligence by his agent in failing to seek a ‘time to pay’ arrangement. 

On 31 January 2023, the appellant’s electronic return was filed for the tax year 2021/22. The tax liability was £54,528, much of which was a capital gains tax liability arising from the appellant’s sale of shares in a company (TP). On 3 February 2023, the appellant’s tax agents (A) contacted HM Revenue and Customs (HMRC), explaining that the appellant had sold his shares in TP, but he would not receive the proceeds until TP completed the sale of a property. Once the sale went through, A stated that the appellant would pay the tax straight away. The HMRC operator stated that they could put a note on record but that it would not stop interest or penalties from