Suspension is not possible because conditions cannot be set

In 2016-17 the taxpayer was director of a company from which she received employment income and dividends. She also had employment income from other sources and a small amount of untaxed bank interest. She was liable to make student loan repayments.

HMRC opened an enquiry into her 2016-17 return. The enquiry letter indicated that the taxpayer had failed to declare some employment income a small amount of bank interest and that she should have made a student loan repayment. The additional tax due was about £1 350 and HMRC also imposed a penalty of about £240.

The taxpayer called HMRC saying she was confused by the letters and requested time to obtain the information from her previous employer. Her accountant said they were unaware of the missing employment income and asked for a suspension of the penalty.

HMRC refused to do this because there were no conditions that it could set...