Failure to comply with information notices

The taxpayer a barrister submitted his tax returns for 2008-09 2009-10 and 2010-11 in April 2012. HMRC was not satisfied that they were correct and issued notices for further information. The taxpayer did not supply all the requested documents and the Revenue imposed penalties under FA 2008 Sch 36 paras 39 and 40.

He was also liable to inheritance tax in his capacity as the personal representative of his father who died in 2005. HMRC had issued an information notice in relation to the inheritance tax return with which the taxpayer had failed to comply.

HMRC applied for permission from the Upper Tribunal to impose tax-related penalties under FA 2008 Sch 36 para 50. This was granted and HMRC issued penalties of £1 075 210. Eventually the taxpayer’s final tax bills came to income tax of £1 250 and inheritance tax...