This may not be what you wish to hear but I am entirely in favour of the abolition of the equitable liability concession at least in its current form.
I would accept its continuation for the very small number of cases where the taxpayer has been prevented by force majeure from supplying the necessary information and documents to HMRC on time for example because of serious illness.
We encounter many deadlines in day-to-day life and failure to observe these often has unfortunate consequences.
For example the entitlement to various social security benefits is lost if the time limit for filing a claim is missed; if someone does not pay a utility bill on time the supply is liable to be cut off; and if we fail to renew an insurance policy we will not be covered if our house burns down the next...
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