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The appellant had owned a tearoom but encountered various problems running it and so sold it. HMRC opened an enquiry into her tax return and requested various business records.
These were not produced and so HMRC issued a TMA 1970 s 19A notice requiring them.
As the documents were still not forthcoming HMRC imposed statutory penalties on the taxpayer. Eventually the department amended the return and issued assessments.
The Special Commissioner commented that the investigation into the appellant’s affairs had been a long one. He said that HMRC had been patient and courteous in the somewhat ‘bizarre actings by the appellant’s agent’.
The agent ultimately did not advance any ‘specific argument which could justify allowing the appeals’.
The commissioner therefore concluded that there was no satisfactory evidence which called into question HMRC’s assessments.
The appellant had had every opportunity to produce...
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