This week's opinion

When a tribunal decision in what appears to be a simple case of penalties for late payment and late filing extends to 179 paragraphs with 13 footnotes you know you are in for an interesting read particularly when the presiding judge is Richard Thomas (Hansard (TC6522)). He always exhibits a great relish for delving into the fine details of the law and of tax history to say nothing of an insistence on getting to the true meaning of words (footnote two is a masterly example of this).

Some people even perhaps a few Taxation readers might argue that this level of analysis is unnecessary perhaps even counterproductive. We all know how the penalty system is supposed to operate and all that is required is a simple yes or no decision in any individual case. But decisions like this show the rules do not always say what we...