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HMRC assessed the taxpayer to penalties and interest arising out of late payment of income tax and late submission of income tax returns for years during 1999-2000 to 2016-17.
The taxpayer accepted that tax had been paid late and that penalties were due but disputed the way HMRC allocated his payments and losses. He made a late appeal which the First-tier Tribunal allowed but the judge issued directions.
In 2022 HMRC applied to have the appeal struck out because the taxpayer had failed to comply with all of the directions.
A second tribunal hearing found that the taxpayer had dealt with two of the three directions and gave the taxpayer another 30 days to comply with the third. This he did but HMRC considered that the information he provided did not comply with the direction and again applied to strike out the appeals.
The instant...
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