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Pointless argument
In August 2004 HMRC issued a TMA 1970 s 19A notice to the taxpayer to provide certain information. They subsequently imposed a penalty of £50 on the taxpayer for not complying with the notice in February 2005. The taxpayer appealed against both the s 19A notice and the penalty but the General Commissioners dismissed his appeal.
In July 2005 HMRC issued another penalty notice imposing daily penalties under TMA 1970 s 97AA(1)(b). The notice wrongly said that it was in respect of the taxpayer's continuing failure to comply with the February 2005 s 19A notice. The taxpayer appealed directly to the Special Commissioners but refused to say why 'due to the conduct of HMRC officers'. Ten days before the appeal hearing however the taxpayer's accountant told HMRC that the appeal was on the grounds that the daily penalty notice was...
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