Employment expenses claimed on travel and expenses were not deductible, as the taxpayer’s travel expenses were ordinary commuting expenses, and the subsistence expenses were not deductible as a matter of principle, such that penalties for deliberate behaviour were upheld.  

The appellant had been a full-time locum doctor in the UK since 2010. During the tax years 2019/20 to 2021/22, the appellant worked at a few NHS Trusts, including Southport & Ormskirk NHS (NHS Southport) and Shrewsbury & Telford Hospital (NHS Shrewsbury). In his self-assessment returns for those tax years, the appellant claimed travel and subsistence expenses. Following enquiries, HM Revenue and Customs (HMRC) issued closure notices for 2019/20 to 2021/22, removing all travel and subsistence expenses claimed by the