No excuse for late appeal

The taxpayer was a barrister who completed her pupillage in 1996 after which she had a short period at the bar before returning to academia.

She went back to the bar in 2003. Her chambers closed two years later and she returned home to care for her sick mother.

The taxpayer joined new chambers in 2005 and appointed an accountant drawing up her accounts on the basis the seven-year rule under which barristers are taxed on the amounts received or invoiced began in 2003/04 not in 1996 when she was called to the bar.

HMRC opened enquiries into the taxpayer’s 2004/05 2005/06 and 2006/07 returns and found her income was understated. The department also discovered her 2003/04 return was incorrect.

The taxpayer said the understated income arose mainly because of her belief the seven-year period began in 2003/04. The Revenue issued assessments and imposed...