Notification situation

The taxpayer company shared a place of business in Essex with its solicitors and a registered office address in London with its accountants.

HMRC sent the taxpayer nine decisions about VAT liability and misdeclaration penalties.

Decisions two three and four were addressed incorrectly. Copies were sent on 2 October 2009 to the solicitors and on 9 November 2009 to the accountants which later received a copy of decision eight dated 16 March 2010.

The Revenue issued assessments on 21 February 2012 relating to periods from 03/06 including copies of decisions two three four and eight. They were addressed to the taxpayer care of the accountants’ London address and included copies of the corresponding notifications of the misdeclaration fines. 

The taxpayer lodged an appeal with the First-tier Tribunal a day later asking to bring late appeals in respect of all nine decisions.

The...