The appellant did not have a reasonable excuse for the late filing of his Self-Assessment return, but the First-tier Tribunal found that special circumstances applied to reduce the late filing penalties imposed.

The appellant filed his Self-Assessment return for the tax year 2017/18 on 24 July 2019. HM Revenue and Customs (HMRC) issued: (1) an initial late filing penalty of £100; (2) daily penalties of £900; and (3) a six-month penalty of £300. The appellant appealed.

The appellant contended he had a reasonable excuse for the late return because (among other things): (1) he had assumed his accountant was completing the tax return; (2) he thought the first HMRC reminder had been sent in error. When more reminders arrived, he tried to contact his accountants, but without success; (3) after contacting HMRC and realising how serious it was, he completed and submitted the return; (4) he would have sent the return before it was overdue had