The taxpayer’s failure to notify chargeability to income tax in respect of property rental income was deliberate but not concealed for penalty calculation purposes. 

Summary 

The taxpayer’s failure to notify chargeability to income tax in respect of property rental income was deliberate but not concealed for penalty calculation purposes. 

Background 

On 16 December 2022, HM Revenue and Customs (HMRC) wrote to the appellant in relation to two properties (FS and ER), which the appellant had been letting out and for which he had been receiving rental income, which HMRC stated had not been disclosed. The appellant replied stating that when he first purchased FS in 2006, he had “submitted a tax return at the end of the year declaring this rental income” and he had “received the attached letter in return dated 22 January 2007 stating that I did not need to