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On 9 August 2006 HMRC opened an enquiry into the taxpayers 2004-05 tax return and requested information relating to his business including purchase ledgers cashbooks bank and credit card statements.
The taxpayer's agent replied on 15 August advising HMRC that the taxpayer was undergoing surgery and chemotherapy for cancer. In reply HMRC offered to collect the records and suggested mandates to enable them to obtain other information directly from the bank etc.
The deadline for the submission of information was extended from 2 October 2006 until 9 November 2006.
The taxpayer did not comply and on 13 November 2006 HMRC issued a formal notice for submission of the records under TMA 1970 s 19A.
The taxpayer appealed. He did not dispute that the records were 'reasonably required' but argued that the notice was wholly unreasonable given his state of health.
The...
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