Reason for the late appeal was not enough

After 22 years in the British Army the taxpayer left and became self-employed. He worked abroad. He hired an accountant to help with his tax returns. He registered for self assessment in July 2015 but on 1 September 2015 the accountant withdrew him. In 2017 the taxpayer took on a new agent.

In October 2018 the taxpayer was selected for an enquiry. HMRC closed this about a year later and issued assessments for £168 963 plus interest. In December 2019 the taxpayer’s then agent asked about a time-to-pay arrangement. In January and February 2020 the agent contacted HMRC about the higher income child benefit charge (HICBC) which had not formed part of the enquiry. In July 2020 HMRC issued assessments for the HICBC for 2016-17 and 2017-18.

The taxpayer continued to try to set up a time-to-pay arrangement with HMRC but to no avail. He made...