The taxpayer’s reliance on pensions advice that was later found to be incorrect was a reasonable excuse for his failure to notify a claim for lifetime allowance enhanced protection in time. 

The appellant (who died before the appeal hearing) was a gastroenterologist for the NHS until his retirement. He appointed a firm of financial advisers (‘O’) in late 2005. In a meeting with a representative of O (‘L’), it was recommended that four pension plans be transferred to a ‘retirement control plan’. L recorded the value of the four pension plans to be transferred as ‘£213,233’. However, the total value of the four plans plus two pensions in payment was £2,120,000.  

In a letter to the appellant advising that the;