Cases cited in the taxpayer’s appeal which were generated by artificial intelligence were not genuine and the taxpayer’s mental health issues and ignorance of the law were not reasonable excuses for her failure to notify chargeability to tax on a property disposal.

In 2006, the appellant purchased a property (SR) for £135,000. SR was let out to tenants from 2007. The appellant did not notify HM Revenue and Customs (HMRC) that she was liable to tax on the rental income. She had never previously completed a tax return. In October 2018, SR was sold for £252,000. The solicitors did not provide the appellant with any advice about capital gains tax (CGT). However, she was aware that there would “…possibly be some tax to pay” and that HMRC “would want money”. Having estimated the CGT payable, the appellant put £20,000 into government bonds. In July 2022, HMRC issued a CGT assessment and charged a penalty of%