The taxpayer’s appeal against certain items listed in an information notice issued by HMRC was struck out as those items were statutory records, and his appeal against other items requested was dismissed as the information was reasonably required for HMRC to check the taxpayer’s tax position. 

During the tax years 2018/19, 2019/20, 2020/21 and 2021/22, the appellant operated a takeaway restaurant. HM Revenue and Customs (HMRC) opened a compliance check in respect of the business and visited the premises. During this visit, the appellant stated that he operated as a sole trader and had started the business approximately 4-5 years earlier. He confirmed that he had not registered for VAT or for self-assessment purposes. Following the visit, on 6 April 2023, the appellant registered for self-assessment, but did not file self-assessment returns for the relevant tax years.  

The information obtained by HMRC prior to the issue of an