This was an appeal by the taxpayer against a decision by HMRC to issue a NoR to provide a security.
The Appellant is 100% owned by Mr Samady and its trading activity is noted as being buying and selling real estate.
HMRC considered that the Appellant represented a risk to the Exchequer due to a number of factors:
- The company had VAT debts of £103,070.78, which included default surcharges of £13,382.45, and a PAYE debt of £96,760.39.
- There had been 10 default periods and the default surcharge rate had been at the 15% rate since 11/16.
- A related company, 37 Victoria Road Ltd, and which was also owned by Mr Samady, had a VAT debt of £411,695.51.
- Another related company, CNM Estates
