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The taxpayer was a solicitor who submitted his 2006/07 tax return in October 2007. During an enquiry HMRC issued a formal request for information under TMA 1970 s 19A.
The taxpayer provided some facts but not all. The Revenue imposed a penalty of £50 under s 97AA against which the taxpayer appealed. He maintained that the taxman was behaving maliciously towards him.
The fines continued to accumulate in the absence of further information from the taxpayer reaching £640.
HMRC decided to transfer the case to another officer who issued a closure notice and discovery assessments for the years 2003/04 to 2005/06.
The taxpayer appealed against the assessments and the penalties.
The First-tier Tribunal found that the information and documentation requested by the Revenue was reasonable if extensive. The department was entitled to issue the penalties in respect of the taxpayer’s refusal to produce the data.
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