Output tax on income from driving lessons

The taxpayer registered for VAT in 2013 when he was working as a courier in the gig economy. He never completed VAT returns only giving his petrol receipts to the courier company each quarter. He did not realise that VAT was charged on the sales he made because the company dealt with the VAT. So when he started trading as a driving instructor in 2014 he submitted his own VAT returns and claimed input tax on his petrol costs and franchise fee but did not account for output tax on the lesson fees. All VAT returns submitted between 2014 and 2018 were therefore repayments with zero output tax.

The problem came to light during a compliance visit in 2018. HMRC issued an assessment for the periods July 2014 to January 2018 based on two errors - output tax due on driving lessons and input tax...