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The taxpayer company’s sole director registered for PAYE online on 7 May 2010. He applied for an activation code in good time but it had expired when it arrived.

The director spoke to the Revenue's helpline but found the online process difficult. He therefore appointed an agent to deal with the matter.

After some difficulty the agent registered the company for online filing on 24 May and activated the system on 3 June. He believed he successfully filed the return on 24 June. However HMRC did not register it.

The taxman issued a late-filing penalty in September 2010 against which the company appealed.

Eventually the Revenue informed the agent that the reason for the return not having been officially received was because the company’s address had been entered incorrectly. The company subsequently filed the return...