On 12 January 2017, HM Revenue and Customs (HMRC) issued blank tax returns to the appellant for the tax years 2013/14 and 2014/15, following a telephone conversation between the appellant, her agent, and an HMRC officer (a tax return for 2015/16 was also issued, which was filed online on 31 January 2017).

HMRC wrote to the appellant on 12 December 2017, which accurately recorded the submission of the appellant’s tax return for 2015/16 on 31 January 2017 and referred to a statement of account dated 23 November 2017, which indicated penalties for the late submission of her tax returns for 2013/14 and 2014/15. HMRC’s records indicated that on 29 August 2017, two 30-day daily penalty reminders were sent to the appellant (one each for 2013/14 and/