Taxpayer’s approach to the appeal was unsatisfactory

The taxpayer traded as a fashion designer. In 2019 she submitted an online appeal form against tax interest and penalties for 2008-09 to 2011-12 and 2013-14 to 2016-17.

The First-tier Tribunal had already heard an appeal by the taxpayer issuing a summary decision (therefore unpublished) in 2015. It had allowed the appeal in part holding that an enquiry notice was valid the taxpayer was entitled to some additional deductions and the penalty should be reduced. It also recommended that HMRC suspend the penalties which it did. There had also been an unsuccessful judicial review application in 2017.

The First-tier Tribunal in the instant appeal considered first the appeals against discovery assessments for 2008-09 2009-10 to 2011-12 and a closure notice. The taxpayer wished to amend her returns to include deductions for professional fees incurred between 2013 and 2017 in relation to the earlier appeal and...