The first appellant, an eminent barrister, submitted his personal tax returns for 2008/09, 2009/10 and 2010/11. HM Revenue and Customs (HMRC) opened an enquiry into those returns, and subsequently issued an information notice (under FA 2008, Sch 36, para 1(1)). The taxpayer only partially complied with the notice, and HMRC issued fixed and daily penalties.

The first appellant was also the personal representative of his late father’s estate. Following the submission of an inheritance tax (IHT) return in respect of the estate, HMRC raised various queries. HMRC later issued information notices, but the appellant did not comply. Various penalties were imposed. HMRC subsequently made applications to the Upper Tribunal (UT) for tax-related penalties (under