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On 17 July 2006 HMRC had issued a notice under TMA 1970 s 19A enquiring into the taxpayer’s 2004/05 tax return.
The taxpayer appealed against the notice but this was dismissed before the Special Commissioner. The High Court then refused an application for a stay of execution of the commissioner’s decision and an appeal to the High Court was also dismissed. An application to appeal to the Court of Appeal was refused on 28 January 2009.
On 18 September 2007 HMRC issued a penalty notice for £50 under TMA 1970 s 100(1) in respect of the failure to produce documents as required by the s 19A notice. The taxpayer appealed against this.
The taxpayer appeared in person before the tribunal and continued his argument against the s 19A notice rather than the penalty.
The judge...
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