Mental ill health

Reasonable excuse for long-term non-compliance

In 2007 HMRC issued tax returns for the years 2001-02 to 2005-06 to the taxpayer who failed to complete them so the Revenue raised estimated assessments. This prompted the taxpayer to submit returns for 2002-03 to 2004-05 which resulted in HMRC amending the assessments for those years. In 2010 it issued assessments for 2005-06 to 2008-09 and imposed penalties. The taxpayer said she had submitted the relevant tax returns but HMRC disputed this. It attempted to enforce the debt in the county court but the proceedings were stayed to give the taxpayer time to lodge a late appeal.

The taxpayer failed to produce evidence that the assessments were wrong so the First-tier Tribunal at an earlier hearing struck out the late appeal. The taxpayer then submitted the outstanding tax returns and applied for special relief. HMRC rejected the...