Corrective action not taken by the deadline

The taxpayer had taken part in an avoidance scheme but had voluntarily withdrawn from it. After an enquiry relating to the years 2005-06 and 2006-07 the taxpayer’s then representative M appealed against the closure notices.

In November 2016 HMRC issued accelerated payment notices and follower notices to the taxpayer. The latter explained that the taxpayer had to take corrective action by February 2017 or he would be liable for a penalty. In February 2017 he made representations against both notices using templates supplied by M. However HMRC upheld the notices and said corrective action should be taken by May 2017. The taxpayer wrote to HMRC again based on a template supplied by M saying he would not taking corrective action. In essence he believed that in paying the sums due on the accelerated payment notices he was taking corrective action.

After more correspondence...